Tribunal Upholds Transfer Pricing Adjustments for Interest-Free Advances to Indian AE Under Base Erosion Theory.

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....Transfer pricing adjustment - interest free advances granted by the assessee to its Indian AE - base erosion theory - Tribunal rejected the the contention of the assessee that, in principle, no arm’s length price adjustments can be made in respect of the interest free advances granted by the assessee to its Indian AE, i.e. Datex Ohmeda India Pvt Ltd. - AT....