No TP Adjustment on AE Receivables as Company Charged No Interest from Both AE and Non-AE Customers

Varun Beverages Limited Vs ACIT (ITAT Delhi) ITAT Deletes Transfer Pricing Adjustment on Receivables Because Higher Profit Margins Already Covered Interest Element; Interest on Foreign Currency Loans to Subsidiaries Held at Arm’s Length Because Rate Exceeded Internal CUP Benchmark; ITAT Removes TP Additions on AE Loans Because LIBOR+400 bps Applied by TPO Ignored Actual Borrowing Benchmark; Transfer Pricing Adjustment on Receivables Deleted Because Transactions Were Linked to Main Sales and Services; ITAT Allows Appeals After Finding AE Loan Interest and Receivables Already at Arm’s Len...