Transfer Pricing Case: Adjustment on Receivables from Associated Enterprises Could Misrepresent Transaction and Alter Characterization.

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....TP Adjustment with respect to receivables from the Associated Enterprises (AE) - With the Assessee having already factored in the impact of the receivables on the working capital and thereby on its pricing/profitability vis-a-vis that of its comparables, any further adjustment only on the basis of the outstanding receivables would have distorted the picture and recharacterized the transaction. - AT....