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2020 (2) TMI 1708 - ITAT BANGALORETP Adjustment towards Stand by Letter of credit - adjustments towards commission for utilization of non-fund based limits of the assessee by Associated Enterprises (AEs) and the Bank has issued SBLC and charged commission - AR contented that there is no requirement of ALP adjustment as the AE is permitted to utilize its non-fund based limits, which is in the nature of shareholders operations and on commercial expediency - HELD THAT:- As vehemently submitted that, there is no necessity of Transfer Pricing adjustment on SLBC because of commercial expediency, But could not controvert the observations and findings of the CIT(Appeals) with cogent evidence. Accordingly, we are not inclined to interfere with the order of CIT (A) on this disputed issue and confirm the same and dismiss the ground of appeal of the assessee.
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