Business Advances Not Loans: Entities Do Not Qualify as Associated Enterprises u/s 92A(2)(c) of Income Tax Act.

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....TP Adjustment - associated enterprises (AEs) - Business advances cannot be construed as loan advanced to the assessee company. Once the same is excluded and the loans given by the aforesaid two entities are considered independently, we find that none of the aforesaid parties had advanced loans more than 51% of book value of total assets of the assessee company. Hence it could be safely concluded that the aforesaid two entities cannot be construed as AEs of the assessee company within the meaning of section 92A(2)(c) - AT....