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TPO was justified in making addition as overdue receivable from AE as way more than shareholders funds of assessee

July 31, 2020[2020] 117 taxmann.com 851 (Delhi - Trib.)

TRANSFER PRICING: Where outstanding receivable from associated enterprise was more than shareholders funds available with assessee implying that total profit earned by assessee was enjoyed by its associated enterprise out of India fully, TPO could not be faulted in considering overdue outstanding receivable from its associated enterprise as a separate international transaction and making addition on account of arm's length price

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