TP Adjustment - TDS deducted on interest paid to AE on External...

TP Adjustment - TDS deducted on interest paid to AE on External Commercial Borrowings - procedure followed by the assessee for grossing up of interest is contrary to agreement between the parties and also contrary to provisions of law. Therefore, we are of the considered view that there is no error in the reasons given by the learned TPO/DRP in disallowing grossed up portion of TDS deducted on interest paid to AE on External Commercial Borrowings. - AT