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No TP adjustments on delay in receipt from AEs if similar delay was there in case of unrelated parties also

September 30, 2019[2019] 109 47 (Delhi - Trib.)

TRANSFER PRICING: Where on DRP's directions to compute ALP on account of corporate charges at 1 per cent of total cost, if total cost of assessee worked out to be higher than what had been paid by assessee towards corporate charges, no adjustment to be made

TRANSFER PRICING: Where assessee had already charged interest at 1.5 per cent over prevailing LIBOR as per loan agreements with its AEs, adjustment on account of interest on foreign currency loan was to be deleted

TRANSFER PRICING: Where assessee was formed as a Special Purpose Vehicle (SPV) for purpose of giving services to group companies and made payment on account of corporate charges, since all transactions were interlinked transactions, transactional net margin method (TNMM) would be most appropriate method

TRANSFER PRICING: Where TPO made TP adjustment on account of reimbursement of expenses without offering any opportunity to assessee, issue to be restored to TPO

TRANSFER PRICING: Where assessee had not charged interest for delay in receipt of remittances from unrelated parties, no adjustment could be made on account of delay in receipt of receivables from associated enterprises

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