COURT: | Bombay High Court |
CORAM: | G. S. Kulkarni J, S. V. Gangapurwala J |
SECTION(S): | 92C |
GENRE: | Transfer Pricing |
CATCH WORDS: | ALP, LIBOR, Transfer Pricing |
COUNSEL: | Vipul J Shah |
DATE: | June 9, 2017 (Date of pronouncement) |
DATE: | June 30, 2017 (Date of publication) |
AY: | 2007-08 |
FILE: | Click here to view full post with file download link |
CITATION: | |
Transfer Pricing ALP of foreign advances: If the advances are made to a AE situated abroad, the LIBOR rate has to considered to determine the Arms Length interest and not the interest rate in India (SBI PLR). This would be reasonable and proper in applying commercial principles |
Advances were made to the company situated abroad. The LIBOR rate naturally will be considered to determine the Arms Length interest, the same would be reasonable and proper in applying the commercial principle. The Tribunal has directed the appropriate rate would be LIBOR plus 2% instead of LIBOR plus 3% applied by the TPO
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