Interest-Free Loan Adjustments Allowed Against Marketing Fees for Transfer Pricing in India.

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....TP adjustments - Notional interest income on the loan (interest free) - the said notional interest income on the loans advanced by the assessee to its AE would be entitled to be adjusted against the expenditure incurred by the assessee by way of marketing service fees paid to its National Marketing Agency in India, i.e its NMC viz. ADSIL.....