Assessee wins on TP adjustment for interest on AE receivables, amalgamation expenditure; Interest relief under 234B, 234C.

The ITAT allowed the assessee's grounds regarding TP adjustment for interest on outstanding receivables from AEs and deduction u/s 35DD. It held that no separate interest on receivables is required to be imputed as the assessee is a debt-free company and working capital adjustment was granted, relying on the decisions in Boeing India and Kusum Health Care. On deduction u/s 35DD, it directed the AO to allow 1/5th of amalgamation expenditure based on the Supreme Court's decision in Goetze India. The ITAT also held that interest u/s 234B is consequential, and u/s 234C should be charged only on returned income, not assessed income. .....

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