No disallowance for non-deduction of tax on provisions made for royalty payment to Russian Co.

IT/ILT: Where assessee sold network security product to AEs and in some cases realization of bills was beyond 90 days, in view of fact that assessee had allowed credit period beyond 90 days in case of Non-Associated Enterprises as well, transactions with non-AE constituted valid Internal CUP and ALP adjustment in respect of interest on account of realisation of bills beyond 90 days from AEs was not justified

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