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2019 (12) TMI 1635 - AT - Income TaxTP Adjustment - Arm’s Length Price (ALP) of the transaction of the interest on loan - DRP directed the TPO to apply LIBOR plus 500 basis points given by the taxpayer’s company to its AE - HELD THAT:- We are of the considered view that transfer pricing adjustment qua the transaction of advancing loan by the taxpayer to its AE is to be determined at US LIBOR plus 170 basis points. Consequently, the TPO is directed to recompute the interest at US LIBOR plus 170 basis points to benchmark the international transactions qua interest on loan by the taxpayer to its AE. Consequently, the appeal filed by the taxpayer is allowed.
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