TP adjustment in absence of interest cost for delay in realisation of dues not sustainable

1. Research and development services provider could not be compared to a company and Transfer pricing Adjustment are not sustainable.

2. A concern mainly engaged in sale of chemical compounds could not be considered as a right comparable with that of assessee rendering support services in connection with research and development of certain products to an AE abroad.

3. Addition made by Assessing Officer on basis of order of TPO on account of interest on delay in real

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