Transfer pricing – Non-charging of interest in the controlled transactions is comparable with that of non-charging from the uncontrolled transactions, no transfer pricing adjustment can be made on this count

Even if we accept the contention of the ld. DR that the non-charging of interest from AEs in the transaction of sale could in itself be construed as an international transaction, then also going by the CUP method, no such adjustment can be made because th0ontrolled transactions is comparable with that of non-charging from the uncontrolled transactions, no transfer pricing adjustment can be made on this count. We, therefore, hold that no addition on account of such interest can be made.

INCOME TAX A

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