TPO Exceeded Jurisdiction with Unjustified Transfer Pricing Adjustment on Vessel Sale by Considering "Opportunity Cost" and Notional Interest.

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....TP Adjustment - sale of an under construction vessel - the TPO by observing that the assessee had lost the “Opportunity cost” had clearly exceeded his jurisdiction. Backed by our aforesaid observations, we are unable to uphold the transfer pricing adjustment worked out by the TPO/DRP as regards the notional interest which as per them the assessee ought to have charged from its AE - AT....