https://www.taxtmi.com/caselaws?id=469875 Transfer pricing adjustments were examined across several transactions. The Tribunal deleted the disallowance for overseas sales support and project management services because the assessee produced agreements, invoices, emails and banking records showing commercially connected services. It restricted corporate guarantee commission to 0.5% on a pro rata basis for the actual guarantee period. Notional interest on overdue receivables from associated enterprises was deleted because no financing benefit or interest policy distortion was shown. The sundry creditor matter was remitted for fresh verification. Transfer pricing adjustments were also held not addable to book profit under section 115JB, as MAT can be altered only by statutory adjustments expressly permitted. en-us Fri, 16 May 2025 00:00:00 +0530 Tue, 07 Jul 2026 21:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469875 Transfer pricing adjustments were examined across several transactions. The Tribunal deleted the disallowance for overseas sales support and project management services because the assessee produced agreements, invoices, emails and banking records showing commercially connected services. It restricted corporate guarantee commission to 0.5% on a pro rata basis for the actual guarantee period. Notional interest on overdue receivables from associated enterprises was deleted because no financing benefit or interest policy distortion was shown. The sundry creditor matter was remitted for fresh verification. Transfer pricing adjustments were also held not addable to book profit under section 115JB, as MAT can be altered only by statutory adjustments expressly permitted. Case-Laws Income Tax Fri, 16 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469875