No notional interest applies to debt-free AE receivables and reimbursed ESOP costs are deductible.
No notional interest applies to debt-free AE receivables and reimbursed ESOP costs are deductible. Issue Whether transfer pricing adjustments by imputing notional interest on outstanding receivables from Associated Enterprises (AEs) are sustainable for a debt-free company, and whether ESOP/ESPP costs reimbursed to a foreign parent company are allowable as revenue expenditure under Section 37(1). Facts… Read More »