Examine with reasons whether the two enterprises referred to in the independent situations given below...
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Accounting
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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