Held that transaction of giving interest-free advance to associated enterprise in foreign currency should be benchmarked by applying LIBOR and not domestic lending rate. Transaction of giving guarantee on a loan availed of by AE is an international transaction. (AY. 2012-13, 2013-14)
Electrosteel Castings Ltd. v. DCIT (2021) 189 ITD 183 (Kol.) (Trib.)
S. 92C : Transfer pricing-Arm’s length price-Interest free advance-LIBOR rate and not domestic lending rate-Loan to AE-International Transaction. [S. 92B]