Transfer Pricing Case: Arm's Length Adjustments Not Allowed for Debt-Free Company's Outstanding Receivables as Loans.

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....TP Adjustments - Arm’s Length adjustment in respect of outstanding receivables - the assessee is a debt free company as is reflected in the profit and loss account - re-characterisation of the outstanding receivables as loan is impermissible unless the transactions are found to be substantially at variance with the stated form.....