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Transfer Pricing Case: No Interest on Receivables in Related and Unrelated Transactions Meets Arm's Length Requirement; TPO Addition Deleted.
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....Transfer Pricing Adjustment - if under both the scenarios, no interest has been charged on similar nature of receivables, then it has to be reckoned that the transaction with the related party meets the arm’s length requirement vis-à-vis, the transactions with the unrelated third parties - addition made by the TPO is directed to be deleted. - AT....
TaxTMI
TaxTMI