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Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)
6 Without prejudice to ground nos. 3 & 4. the learned AO/TPO erred in ignoring that, if at all transfer pricing adjustment to be sustained with respect to notional interest on overdue receivables, it should be restricted to AEs outstanding for more than 150 days. 7. Without prejudice to ground nos. 3 & 4, the learned AO/TPO erred in ignoring that