Held that interest on outstanding receivables due from AE is an international transaction requiring separate benchmarking; since the loan attributable to the AE is deemed to have been consumed in a country outside India, the arm’s length interest rate on similar foreign currency receivables/advances is to be taken as LIBOR+200 points. (AY. 2017-18)
Aurobindo Pharma Ltd v. ACIT (2024) 231 TTJ 81(UO) (Hyd)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on receivables-Interest on outstanding receivables from AE-International transaction-60 days and 240 days-The arm’s length interest rate on similar foreign currency receivables/advances is to be taken as LIBOR+200 points. [S.92B]
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