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| The Tax Publishers2019 TaxPub(DT) 4179 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
As regards interest on foreign currency loans LIBOR rate had to be considered as at arm's length and since assessee had advanced loan on LIBOR plus basis, no ALP adjustment was called for.
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Transfer pricing - Determination of ALP - Granting of foreign currency loan to AE -
Assessee extended foreign currency loan to AE its abroad at LIBOR rates. TPO considered domestic PLR as arm's length interest rate and accordingly proposed TP adjustment.Held: As regards interest on foreign currency loans LIBOR rate had to be considered as at arm's length and since assessee had advanced loan on LIBOR plus basis, no ALP adjustment was, therefore, called for.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2011-12 & 2012-13
INCOME TAX ACT, 1961
Section 36(1)(va) Section 43B, Proviso
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