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TMI Blog2021 (6) TMI 1087X X X X Extracts X X X X X X X X Extracts X X X X ..... term deposit rate in the State Bank of India and therefore, the same deserves to be upheld - HELD THAT:- We find no merit in Revenue s instant argument since such a short term deposit cannot be taken at par with an international transaction u/s.92B of the Act as the latter involves foreign currency and overseas market conditions. In addition to this, learned lower authorities have also not ado ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n appeal No.10079/2018-19/B3/CIT(A)-6, involving proceedings u/s.143(3) r.w.s.92CA(3) of the Income Tax Act, 1961 [in short, the Act ]. Heard both the parties. Case file perused. 2. The assessee s sole substantive grievance pleaded in the instant appeal challenges correctness of the lower authorities action making arm s length price ALP adjustment of ₹ 75,60,985/- qua interest on r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as well as the CIT(A) have rightly treated the foregoing bench mark as per the short term deposit rate in the State Bank of India and therefore, the same deserves to be upheld. 4. We find no merit in Revenue s instant argument since such a short term deposit cannot be taken at par with an international transaction u/s.92B of the Act as the latter involves foreign currency and overseas market c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iii. Open Text Corporation India Private Limited, ITA No. 152/Hyd/2017, dt.19-05-2021; iv. Hexagon Capability Center India Private Limited, ITA No. 2032/Hyd/2017, dt.26-11-2020; No other ground has been pressed before us in assessee s Form-36 filed in the tribunal. 5. This assessee s appeal is allowed in above terms. Order pronounced in the open court on 18th June, 2021 - - TaxTMI ..... X X X X Extracts X X X X X X X X Extracts X X X X
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