ITAT set aside TP adjustment as no uncontrolled transactions were identified for comparison

IT/ILT: Where in respect of interest free advances given by assessee to its wholly owned overseas subsidiaries, TPO made adjustment at 14 per cent rate of interest based on LIBOR, following order passed by co-ordinate Bench of Tribunal in assessee's own case relating to earlier assessment year, impugned adjustment was to be set aside holding that TP adjustment was possible only in cases where comparable uncontrolled transactions entered into between two enterprises were established