Tata Motors Ltd. v. CIT (2019) 177 ITD 327 (Mum.)(Trib.)

S. 92C : Transfer pricing–Arm’s length price-Loan to AEs without charging interest–Interest rate could not exceed LIBOR plus 200 basis points–Remanded to TPO for examination.

Before the Tribunal the assessee contended that Interest rate could not exceed LIBOR plus 200 basis  points. Matter remanded to TPO for examination.  (AY. 2007 -08)