Assessee was engaged in providing ship management and consultancy services. Transfer pricing Officer (TPO) held that overall management and control of assessee company lied with management of companies SSML, PSML and UML.  DRP  held that assessee had received certain amount from SSML and PSML but these two entities had not provided any service to assessee and, thus, these amounts could not be considered as credits availed during course of business and same could only be considered as loans advanced by them to assessee-Accordingly, he held that SSML and PSML would become AEs of assessee by deeming fiction in terms of section 92A(2)(c) of the Act. On appeal the Tribunal held that as per mandate of section 92A(2)(c) each of enterprise should have advanced loan to assessee constituting more than 51 per cent of book value of total assets of assessee so as to be considered as AEs of assessee by deeming fiction, since none of two entities had individually advanced loan of more than 51 per cent of book value of total assets of assessee and these entities had jointly given loans of more than 51 per cent of book value of total assets of assessee, these two companies could not be deemed as AEs of assessee as per section 92A(2)(c) of the Act. (AY. 2011-12)