Tribunal Orders Reassessment of Transfer Pricing Adjustments on Notional Interest for Delayed AE Receivables.

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....TP Adjustment - notional interest on outstanding receivables due from Associated Enterprises (AES) - assessee not charging any interest from its AEs - Treatment of outstanding receivables as a separate international transaction - Common policy of not charging interest on delayed payments from AEs and third parties - Ultimately, the ITAT partly allowed the assessee's appeal, directing adjustments to be computed following the directions of the DRP. This included considering the receivables cleared within specific timeframes and applying appropriate interest rates. - The Tribunal emphasized the need for a case-by-case examination of transactions and directed the AO to set off receivables cleared within certain periods.....