For Similar Transactions with Related and Unrelated Parties if Price is Comparable, It is taken to be at ALP

Advertisement Axis Risk Consulting Services Private Limited. Vs DCIT (ITAT Delhi) the only dispute before us is with regard to the adjustment by way of imputing interest @ 17.22% by the TPO on account of receivables from the AE. Here in this case, it is an undisputed fact that the assessee has also rendered similar services to non AEs/unrelated parties and on receivables from the non AEs also, there have been delays on receivables on which no interest has been charged by the assessee. Before us, invoice wise details have been furnished highlighting the details of amount of the invoice date;...