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2021 (9) TMI 1422 - AT - Income TaxTP Adjustment - Enhancement of income of the assessee on account of interest on receivables from the AEs - assessee contending that the authorities below failed to appreciate the fact that the assessee has not been charging any interest from third-party customers as an outstanding receivable and pricing/profitability is more than the working capital adjusted margin HELD THAT:- In Kusum Healthcare Private Limited [2017 (4) TMI 1254 - DELHI HIGH COURT] held that no additional imputation of interest on the outstanding receivables is warranted if the pricing/profitability is more than the working capital adjusted margin of the comparables Once the working capital adjustment is given, it subsumes the interest on receivables and no separate benchmark for it has to be made. Respectfully following the view taken by the Hon’ble jurisdictional High Court in the case of Kusum Healthcare (supra), we hold that the addition made on account of interest on receivables cannot be sustained. - Decided in favour of assessee. Non-grant of credit of entire TDS - HELD THAT:- Both the counsel agreed on the point that it would be suffice if the learned Assessing Officer is required to verify and grant the credit of TDS as per law. We direct the learned Assessing Officer to verify and grant the TDS under law.
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