In the result, the appeal of the assessee in ITA No
Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia
section 92A(2)(c) of the Act was not satisfied since the loan advanced did not constitute ITA Nos.923 & 924/Hyd/2024 21 51% of the book value of total assets on the date of agreement. Accordingly, the lender and the assessee cannot be treated as Associated Enterprises (“AEs”), and no benchmarking is permissible. In their second contention, the Ld. AR submitted