Tribunal Overturns Transfer Pricing Adjustment, Validates Assessee's Analysis and Deletes Imputed Interest After Adjustments.

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....Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through agreement, correspondence, invoices, payments, and improved revenue and profitability. The Dispute Resolution Panel arbitrarily upheld the Transfer Pricing Officer's determination of nil value without examining facts and legal precedents. The Tribunal set aside the adjustment, reinstating the assessee's transfer pricing analysis using the Transactional Net Margin Method. Regarding imputed interest on delayed receivables, the Tribunal followed precedents that working capital adjustment subsumes interest on receivables, eliminating separate benchmarking. As the assessee's prof.........