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No additions for notional interest as no arrangement found between parties for delayed payment

February 3, 2020[2020] 113 393 (Delhi)

TRANSFER PRICING: Where TPO made addition towards interest on delayed payment, however perusal of transactions undertaken by assessee with AE showed no pattern discernible which would suggest any arrangement or understanding between assessee and its AE that would qualify said transaction as an international transaction, no addition could have been made

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