https://www.taxtmi.com/caselaws?id=210794 The Tribunal dismissed the Revenue's appeals for AY 2003-04 and AY 2004-05, upholding the inclusion of Clingene International Pvt. Ltd. as a comparable company, the non-requirement of Arm's Length Price adjustments due to the safe harbor rule, and the deletion of interest disallowance on an interest-free loan to Monsanto India Ltd. The Tribunal stressed the significance of functional comparability and commercial expediency in transfer pricing and interest disallowance matters. en-us Wed, 09 Nov 2011 00:00:00 +0530 Wed, 22 May 2013 10:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210794 The Tribunal dismissed the Revenue's appeals for AY 2003-04 and AY 2004-05, upholding the inclusion of Clingene International Pvt. Ltd. as a comparable company, the non-requirement of Arm's Length Price adjustments due to the safe harbor rule, and the deletion of interest disallowance on an interest-free loan to Monsanto India Ltd. The Tribunal stressed the significance of functional comparability and commercial expediency in transfer pricing and interest disallowance matters. Case-Laws Income Tax Wed, 09 Nov 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210794