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2018 (8) TMI 757 - HC - Income TaxTransfer pricing - arms length interest rate on loan - loan given to Associated Enterprise - Arms length price on corporate guarantee - Held that:- the assessee considered the markup on the basis of the average spread over LIBOR charged in whole European region. The learned CIT(A) as well as the learned ITAT has also considered the submission on behalf of the Revenue that even the condition prevailing in the country was required to be considered as the same has also been dealt with and considered for which necessary observations are made in para 4.3 itself. - no substantial question of law in this issue. Appeal admitted on the following ground: Whether the Appellate Tribunal has substantially erred in law in deleting the addition of ₹ 3,01,66,650/being Arms length price on corporate guarantee?
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