TP Adjustment - The interest on receivables is an international ...

Interest on Receivables in Foreign Currency: LIBOR Plus Margin Applies, Not SBIPLR, per Section 92B Amendment.

January 1, 2021

Case Laws Income Tax AT

TP Adjustment - The interest on receivables is an international transaction as it is subsequent to the amendment to section 92B of the I.T. Act - We are inclined to accept the alternate argument of the assessee that since the receivables are in foreign currency, the rate of interest to be applied is at LIBOR + and nor SBIPLR rate. - AT

View Source

← Previous Next →

TP Adjustment - The interest on receivables is an international ...

Interest on Receivables in Foreign Currency: LIBOR Plus Margin Applies, Not SBIPLR, per Section 92B Amendment.

January 1, 2021

Case Laws Income Tax AT

You may also like:

TP Adjustment made on account of interest chargeable on outstanding receivables - applying LIBOR rates - adoption of SBI prime lending rate @14.45% is definitely...

Outstanding receivables from AEs exceeding agreed credit period constitutes separate international transaction of providing capital financing/lending receivables, not...

Appropriate rate for benchmarking - receivables from AEs - it would be most appropriate if the LIBOR rate is applied as most appropriate rate of interest for imputing...

The ITAT Hyderabad addressed a Transfer Pricing (TP) Adjustment issue regarding interest on outstanding receivables, determining if it constitutes an international...

TP Adjustment - Interest on loans and advances given to the AEs - Interest rates vary and are thus dependent on the foreign currency in which the repayment is to be made...

The ITAT held that interest payments on Compulsorily Convertible Debentures (CCDs) denominated in Indian currency must be benchmarked against domestic interest rates,...

TP adjustment for corporate guarantee commission at 0.50% on guaranteed amount directed. Interest on receivables beyond agreed credit period of 60-240 days for non-AEs...

TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held...

TP Adjustment - delayed receivables from AE - re-characterizing the delay in receipt of receivables as unsecured loan, the AO computed interest by applying rate of 4.33%...

TP adjustment to payment of interest on ECB loan - TPO himself has stated that while granting permission to the assessee for availing ECB loan, the RBI has fixed the...

DRI busted Foreign Currency Smuggling Racket involving Foreign Nationals; Foreign Currencies worth ₹ 6.14 crore seized

TP Adjustment - notional interest on outstanding receivables due from Associated Enterprises (AES) - assessee not charging any interest from its AEs - Treatment of...

TP Adjustment - Impute interest on receivables - LIBOR + 200 basis point rate is most appropriate rate and hence, direct the AO/TPO to adopt LIBOR + 200 basis point for...

TP adjustment - Benchmarking of interest on interest free advances good to the subsidiary companies - In the present case, the cost borrowing of the assessee does not...

The ITAT directed exclusion of three companies (Wipro Limited, Infosys Ltd., and Tata Elexi Limited) as comparables for transfer pricing adjustments, relying on...

Quick Updates: