https://www.taxtmi.com/caselaws?id=800090 Delayed realization of receivables from associated enterprises may constitute a separately benchmarkable international transaction because deferred payments, receivables and business debts fall within that scope. Working capital adjustment, calculated from opening and closing receivable and payable balances, does not automatically capture invoice-specific delays beyond agreed credit periods. However, a notional-interest transfer-pricing adjustment is unwarranted where the taxpayer is debt-free and there is no evidence of interest cost, reduced profitability, or a financing benefit conferred on an associated enterprise. Delayed recovery alone does not establish an arm's length financing charge in those circumstances. en-us Mon, 07 Sep 2026 00:00:00 +0530 Thu, 01 Oct 2026 07:40:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800090 Delayed realization of receivables from associated enterprises may constitute a separately benchmarkable international transaction because deferred payments, receivables and business debts fall within that scope. Working capital adjustment, calculated from opening and closing receivable and payable balances, does not automatically capture invoice-specific delays beyond agreed credit periods. However, a notional-interest transfer-pricing adjustment is unwarranted where the taxpayer is debt-free and there is no evidence of interest cost, reduced profitability, or a financing benefit conferred on an associated enterprise. Delayed recovery alone does not establish an arm's length financing charge in those circumstances. Case-Laws Income Tax Mon, 07 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800090