Transfer Pricing Adjustment - TPO's reliance on loan data from the US and Europe for benchmarking is...

Transfer Pricing Adjustment - TPO's reliance on loan data from the US and Europe for benchmarking is inappropriate given Bahrain's distinct economic environment and sovereign risks. The Prime Lending Rate of Bahrain's Central Bank already incorporates regional factors and risks. Adding spreads for country and forex risks constitutes duplicative adjustments. CUP method necessitates adjustments only if materially impacting price. Assessee's consistent application of interest calculation method underscores reliability. CIT(A)'s order upholding fair benchmarking and appropriate risk adjustments is upheld, dismissing TPO's adjustment. Non-deduction of withholding tax u/s 195 - Product Certification Expenses paid to non-residents do not constitut..... .....

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