Allowing the appeal of the assessee, the Tribunal held that investment in share capital of subsidiaries outside India. Advancing towards investment and for expansion of business out of interest free funds interest cannot be charged . Transaction is not in nature of international transaction hence transfer pricing provisions is not applicable . Accordingly adjustment is not required . ( AY.2008-09 to 2011-12 )
Bartronics India Ltd. v. DCIT (2018) 65 ITR 540/ 195 TTJ 314 (Hyd) (Trib)
S.92B: Transfer pricing- International transactions — Investment in share capital of subsidiaries outside India — Advancing towards investment and for expansion of business out of interest free funds — No interest can be charged — Not in nature of international transaction-Transfer pricing provisions is not applicable — Adjustment is not required .[ S.92C ]