Held that  all international transactions between associated enterprises were primarily guided by the principle of commercial expediency.  The amounts advanced by the assessee towards the associated enterprises were inextricably linked with export sale of finished goods or yielded economic benefits to the assessee or that the advances were given out of interest-free funds available with the assessee, were irrelevant consideration while deciding the issue of charging of interest by the assessee from its associated enterprises since transfer pricing in respect of international transactions between associated enterprises was to ensure that there was no tax-base erosion at the India level nor shifting of profits to an overseas jurisdiction with a view to avoid taxes. Matter remanded to CIT(A).    (AY.2009-10, 2010-11, 2011-12)