TNMM in Transfer Pricing Covers Notional Interest Costs, Removes Upward Adjustments on Delayed Export Receivables from Associated Enterprises.

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....TP Adjustment - when TNMM method has been applied as most appropriate method it could take care of all notional interest costs wherever it could be applied and there could be no separate upward adjustments on export receivables for belated realization of export bills. Hence, we direct the Assessing Officer to delete upward adjustment made towards overdue receivables from Associated Enterprises. - AT....