ITAT Cochin Judgments — April 2018

The Tribunal remitted the transfer pricing adjustment issue back to the AO for a fresh TP study. It also ruled in favor of the assessee regarding the disallowance of notional interest on working capital loans, following a jurisdictional High Court decision.

The Tribunal held that while the assessee was liable for tax deduction at source on merits, the order passed under sections 201(1) and 201(1A) was barred by limitation as it was passed beyond a reasonable time.

The Tribunal remitted the transfer pricing adjustment issue back to the AO for a fresh TP study. It also ruled in favor of the assessee regarding the disallowance of notional interest on working capital loans, following a jurisdictional High Court decision.