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 applied Transactional Net Margin Method (TNMM) method and concluded that transaction was at arms length. However, the TPO noticed on an analysis of the financial transactions of the assessee that the amount of USD 7 million was cla...