TPO Must Use Annual Average Collection Period for Transfer Pricing Adjustments on Receivables Exceeding 90 Days.

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....TP Adjustment - ALP of interest on receivables - no credit period was agreed between the parties - TPO should not calculate the collection period selectively which are beyond 90 days, he has to calculate the average of collection for the year under consideration of all the transactions - the adjustment only to the extent it crossed 90 days....