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2022 (3) TMI 1504 - AT - Income TaxTP Adjustment - assessee has given loan to its A.E. and hence, the TPO has adopted prime lending rate prescribed by the State Bank of India - HELD THAT:- We notice that the TPO has adopted external CUP for making this transfer pricing adjustment. Before us, the assessee could not furnish any material to controvert the reasoning given by the TPO. AO has computed interest on the closing balance - The ledger account of Eurocor - We notice that there was opening debit balance and during the year under consideration, the assessee has advanced further amounts on various dates. Hence, in our view, the TPO should have computed interest on time basis. Accordingly he was not justified in computing interest for the entire year on the closing balance. Accordingly, while upholding the view of TPO that transfer pricing adjustment is required to be made on the loan given to the AE, we restore this issue to the file of AO/TPO for re-computing interest on time basis. Appeal filed by the assessee is treated as partly allowed for statistical purposes.
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