No separate notional interest adjustment when working capital adjustment made under TNMM

ACIT Vs Intas Pharmaceuticals Ltd (ITAT Ahmedabad) ITAT Ahmedabad held that upward adjustment on account of notional interest on outstanding receivables rightly deleted since TNMM has been applied and working capital adjustment has been given while benchmarking the main international transaction. Facts- The present appeal has been filed by the revenue. It is mainly contested the deletion of upward adjustment of Rs.1,27,16,929/- made by the TPO/A0 by applying LIBOR with a different mark­up and further addition of 100 basis points towards alleged forex risk adjustment in respect of loans advan...