Dismissing the appeal of the revenue the Court held that Reserve Bank of India had given approval with regard to said rate of interest adopted by assessee which was a relevant factor to determine rate of interest. TPO had accepted such rate of interest adopted by assessee for assessment years 2002-03 to 2008-09 except for relevant assessment year 2006-07.Revenue could not be allowed to make a departure in case of rate of interest for relevant assessment year. (AY 2006-07)
CIT v. GE India Technology Centre (P) Ltd. (2021) 278 Taxman 261 (Karn.)(HC)
S. 92C : Transfer pricing-Arm’s length price-Interest rate-Accepted earlier year as well as subsequent assessment years-Revenue could not be allowed to make a departure in case of rate of interest for relevant assessment year.