RBI’s approval does not put a seal of approval on true character of a transaction from perspective of transfer pricing regulation

RELEVANT PARAGRAPH These appeals by the assessee are directed against the separate orders of the CIT(A) for the respective assessment years. Since the issues involved in these appeals are common and connected, and these appeals were heard together, these are being consolidated and disposed of together by this common order. 2. One common issue raised is that the CIT(A) erred in not accepting the interest free loan extended to the associated concerns as at arm’s length. 3. The facts of the case are as under:- Perot Systems TSI (India) Private Limited (PSTSI) is engaged in the business of d...