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Examine with reasons whether the two enterprises referred to in the independent situations given below can be deemed to be associated enterprises under the Indian
Examine with reasons whether the two enterprises referred to in the independent situations given below can be deemed to be associated enterprises under the Indian transfer pricing regulations: (i) PQR Inc, a US company having its place of effective management also in the USA, has advanced a loan equivalent to 170 crores to Mahanadi Ltd., an Indian company on 10-4-2021. The total book value of assets of Mahanadi Ltd. is 300 crores. The market value of the assets, however, is 320 crores. Mahanadi Ltd. repaid 30 crores before 31-3-2022. (ii) Queenland plc., a French company having its place of effective management also in the France, has the power to appoint 3 of the directors of Godavari Ltd, an Indian company, whose total number of directors in the Board is 8 . (iii) Total value of raw materials and consumables of Saraswati Ltd., an Indian company, is 900 crores. Of this, supplies to the tune of 830 crores are by Zoel GmbH, a German company having its place of effective management in Germany, at prices and terms decided by the German company
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