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Income Tax - Highlights / Catch Notes

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TP Adjustment - Notional interest - interest-free advances ...


Court Upholds Transfer Pricing Officer's Adjustment on Interest-Free Advances to Associated Enterprise Under Scrutiny.

May 9, 2023

Case Laws     Income Tax     AT

TP Adjustment - Notional interest - interest-free advances extended by the assessee to its AE - In an uncontrolled condition and between persons other than associated enterprises, no prudent person would have given huge loans to a third party and reduce the same by making a provision for bad and doubtful loans and advances. - we confirm the findings of the TPO in making the TP adjustment on interest free loans given to AEs. - AT

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