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2023 (10) TMI 972 - AT - Income TaxTP Adjustment - notional interest on receivable - TPO held that the delayed payment are being treated as unsecured loan advance to the AE and charged the interest at 12.51% i.e. 6 months labor + 400 basic point for commuting notional interest for the delayed period - HELD THAT:- By respectfully following the above order of the Co-ordinate Bench in assessee’s own case for AY 2016-17 [2021 (7) TMI 831 - ITAT DELHI] we are of the considered opinion that since the assessee found to be ‘debt free company’, the action of the revenue making adjustment on account of notional interest on the receivable cannot be justified. Consequently, Ground of the assessee are allowed.
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