Can notional interest be taxed under transfer pricing law ?

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Yes, under transfer pricing mechanism , there is scope of notional interest taxation.  This is held by Delhi bench F in Perot Systems TSI ( India) Ltd. vs. DCIT, ITA No. 2320 to 2322/Del/08, Delhi Bench ‘F’ order dated 30.10.2009. Facts of the case The aseessee, an India company, advanced interest free loans to its 100% foreign subsidiaries….

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