Transfer Pricing – ALP of Interest-Free Loan – ITAT Delhi Explains Law

M/s Aithent Technologies Pvt Ltd. V/s. ITO (ITAT Delhi)- Indisputably, the aforesaid international transaction of interest free loan to the AE is an independent transaction ,requiring determination of ALP. The assessee in their transfer pricing study inferred that no external comparable uncontrolled price was available for bench marking this transaction and thus, it

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