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2017 (12) TMI 197 - AT - Income TaxRate of interest for the purpose of computation of arm’s length price - determination of arms' length rate of interest - Held that:- In the case in hand before us, the invoices have been raised in Australian Dollars and US Dollars and these amounts are receivables to the assessee, therefore, the receivables are payable to the assessee in respective currencies. Thus, following the finding of the Hon’ble Delhi High Court in the case of Cotton Naturals (I) (P) Ltd. (2015 (3) TMI 1031 - DELHI HIGH COURT ), we direct the AO/TPO to compute the interest rate applying the LIBOR rate prevalent during the relevant period in case of Australian Dollar/US Dollar plus suitable basis point keeping in view the credit score of the AEs. Accordingly, we restore the issue of computation of arm’s length price of the international transaction of the receivables in the case of the assessee in view of the above directions. The assessee shall be afforded adequate opportunity of being heard. The ground of the appeal is accordingly allowed partly for statistical purposes.
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