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Delay in realization of trading debt from AE may attract TP adjustments towards notional interest

March 6, 2019[2019] 102 taxmann.com 439 (SC)

IT/ILT : SLP dismissed against High Court ruling that where services rendered by assessee were specialized and required specific skill based analysis and research that was beyond rudimentary nature of services rendered by a BPO, it was to be held services provided by assessee constituted functions of a KPO

IT/ILT : SLP dismissed against High Court ruling that if there is any delay in realization of a trading debt arising from sale of goods or services rendered in course of carrying on of business, assessee is liable to be visited with transfer pricing adjustment on account of interest income short charged/uncharged

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