Held, that in terms of the Tribunal’s order in the assessee’s own case for the AY.s 2007-08 and 2008-09, the deletion of addition was upheld on the ground that on loans advanced in foreign currency the interest ought to be estimated in terms of a foreign-currency loan and not a rupee-denominated loan. (AY. 2010-11, 2011-12).
Dabur India Ltd. v. Dy. CIT (2023)101 ITR 148 (Delhi) (Trib)
S. 92CA : Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax Reference to Transfer Pricing-Loan to overseas subsidiaries in foreign money-Interest to be estimated as foreign-currency loan and not rupee denominated loan-International libor rates to be taken as benchmark.