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2022 (12) TMI 1203 - AT - Income TaxTP adjustment made in respect of interest on delayed receivables - As submitted that the assessee has received advances from the AE in some cases, which should have been netted off - HELD THAT:- We are of the view that there is merit in his contentions. As rightly submitted by Ld A.R, the Arm’s Length Price of transactions have to be determined by following any one of the methods prescribed under the Income tax Rules. Admittedly, the TPO/DRP, in the instant case, has not followed the same. Accordingly, we deem it proper to restore this issue to the file of AO/TPO for determining the ALP, i.e., interest on delayed receivables by following the rules. The assessee is free to raise all the contentions before the AO/TPO. Appeal filed by the assessee is treated as allowed for statistical purposes.
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