Interest Rate Variance on FCCDs Within Limits; Tax Officer's Adjustment Unwarranted, Income Addition to Be Removed.

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....TP adjustment - interest paid by the assessee to its Associated Enterprise [AE] - variance does not exceed 5% for the FCCDs issued during the FYs 2008-09 and 3% for the FCCDs issued subsequently interference by the Ld. TPO with the value of the international transaction. The addition, therefore, cannot be sustained and shall be directed to be deleted. - AT....