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2023 (2) TMI 1105 - AT - Income TaxTP Adjustment - interest on outstanding receivables - Outstanding receivables from unrelated parties - HELD THAT:- We find force in the contention of assessee. Since the assessee has provided similar services to unrelated parties and claims that no interest was charged with respect to outstanding receivables from unrelated parties, in all fairness, this contention cannot be brushed aside lightly, though needs due verification by lower authorities. We, therefore, restore this issue to the file of the TPO/AO. The assessee is directed to furnish necessary documentary evidences to demonstrate that on outstanding receivables from unrelated parties, no interest was charged on similar transactions as that with AEs and the AO/TPO is directed to examine the same and decide the issue afresh as per provisions of law. In light of the above, if the AO/TPO, after verification, finds that no interest was charged from receivables from non-AEs on similar transactions, then no adjustment is warranted. Appeal of the assessee is allowed for statistical purposes.
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