During relevant year assessee gave interest free ECB loan to its wholly owned subsidiary in India. Assessing Officer made addition to assessee’s ALP in respect of notional interest on said loan. Tribunal held that that ALP of notional interest on interest free loan advanced by assessee was to be taken as LIBOR rate plus 2 per cent. Followed the order of earlier year. (AY. 2013-14)
Sabre Asia Pacific Pte. Ltd. v. DCIT (2020) 183 ITD 832 (Mum.) (Trib.)
S. 92C : Transfer pricing-Arm’s length price-Notional interest on interest free loan-Rate of LIBOR plus 2 per cent is held to be justified.