TMI Blog2018 (11) TMI 1693X X X X Extracts X X X X X X X X Extracts X X X X ..... cting the rate of interest at 0.5% on corporate guarantee given by the Assessee to its Associated Enterprise instead of 6% proposed by the Transfer Pricing Officer - HELD THAT:- Both the questions for our consideration stand concluded against Revenue and in favour of the Respondent Assessee by the decision of this Court in CIT Vs. M/s Everest Kanto Cyliners Ltd. [ 2018 (7) TMI 2048 - BOMBAY HIGH C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ollowing two questions of law for our consideration: 1. Whether, on the facts and in the circumstances of the case and in law the Hon'ble Tribunal was justified, in terms of Section 92C of the Act read with Rule 10B of the I.T. Rules, in restricting the rate of interest at 'LIBOR + 2%' on loans given by the Assessee to its Associated Enterprise instead of 17.26% proposed by t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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