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The ITAT set aside the Transfer Pricing Officer's addition of notional interest on loans advanced to the assessee's associated enterprises (AEs), noting that the assessee did not charge interest on receivables from non-AEs, thereby negating any basis for adjustment on AE transactions. The tribunal held that neither the TPO nor the CIT(A) was justified in sustaining the addition of notional interest on outstanding AE receivables. Consequently, the appeal concerning interest adjustments for all three assessment years was allowed. Regarding the notional commission on corporate guarantees, the ITAT directed the Assessing Officer to apply a 1% commission rate, consistent with the tribunal's prior ruling in the assessee's own case. This order effectively reduces the transfer pricing additions and limits the corporate guarantee commission to a prescribed rate.
The ITAT set aside the Transfer Pricing Officer's addition of notional interest on loans advanced to the assessee's associated enterprises (AEs), noting that the assessee did not charge interest on receivables from non-AEs, thereby negating any basis for adjustment on AE transactions. The tribunal held that neither the TPO nor the CIT(A) was justified in sustaining the addition of notional interest on outstanding AE receivables. Consequently, the appeal concerning interest adjustments for all three assessment years was allowed. Regarding the notional commission on corporate guarantees, the ITAT directed the Assessing Officer to apply a 1% commission rate, consistent with the tribunal's prior ruling in the assessee's own case. This order effectively reduces the transfer pricing additions and limits the corporate guarantee commission to a prescribed rate.
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