Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

5. Ground No.3 to 7 raised by the Assessee pertains to transfer pricing adjustment in relation to notional interest on (a) loans/advances to AEs, and (b) receivables outstanding from AEs. Ground No. 3 to 7 read as under: 3 Assessment Year 2013-2014 “Imputation of notional interest “3. On the facts and circumstances of the case