TMI Blog2019 (8) TMI 512X X X X Extracts X X X X X X X X Extracts X X X X ..... the Court had held following Principal CIT vs. Bechtel India (P) Ltd. [ 2016 (9) TMI 196 - DELHI HIGH COURT] that such notional income on account of delayed payment by the A.E. cannot be treated as part of the income and made the subject matter of the adjustments. This Court is of the opinion that since no amounts were advanced in the instant case, rather the adjustments made on account of T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Income Tax Act, 1961. 2. The assessee s income tax returns were subject to ALP determination by the TPO who added various amounts in the two assessment years i.e. A.Y. 2013-2014 and 2012-2013. The assessee appealed to the Appellate Commissioner, one of the contentions urged was that a similar exercise for 2009-2010 had been challenged and the adjustment made was set aside and the same w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 16 decided on 21.07.2016] that such notional income on account of delayed payment by the A.E. cannot be treated as part of the income and made the subject matter of the adjustments. 5. This Court is of the opinion that since no amounts were advanced in the instant case, rather the adjustments made on account of TPO that ought to have been recovered from the notional interest, on a subjec ..... X X X X Extracts X X X X X X X X Extracts X X X X
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