Arm's Length Price for interest on intra-group loans remanded after Tribunal omitted to decide the transfer pricing issue.

The Tribunal had not adjudicated the Arm's Length Price of interest on loans extended by the assessee to its Associated Enterprises, and that omission was accepted on record. The appellate court therefore interfered only to that limited extent, set aside the impugned order on the undecided transfer pricing issue, and remanded the matter for reconsideration while leaving the remaining findings undisturbed.

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Issues: (i) Whether the Tribunal's order required interference to the extent it had not adjudicated the issue relating to ascertainment of Arm's Length Price on interest-bearing loans extended by the assessee to its Associated Enterprises.

Analysis: The record showed that the specific issue concerning Arm's Length Price of interest on loans extended to Associated Enterprises had not been dealt with by the Tribunal. As the omission was accepted, the appellate court confined its interference to that limited aspect and directed that the matter be sent back for consideration of the undecided issue, while leaving the remaining parts of the order intact.

Conclusion: The impugned order was set aside only to the limited extent of the Arm's Length Price issue concerning interest on loans, and the matter was remanded for reconsideration on that question.

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