Geographical location of market won’t impact comparable unless market conditions are materially diff

IT/ILT: Geographical location of market is of no consequence in judging comparability of an uncontrolled transaction under CUP method, unless market condition in which uncontrolled transactions have taken place are materially different - Held, Yes - No TP adjustment to be made on account of single transaction and unsecured loan extended to foreign subsidiary, on the reasoning that the subsidiary is under management and control of the lender-parent company, and the business risk is much lower - H