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Income Tax - Highlights / Catch Notes

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TP adjustment - Benchmarking of interest on interest free ...


Interest-Free Advances to Subsidiaries: LIBOR Plus 200 Basis Points Upheld for Transfer Pricing Adjustment.

September 12, 2022

Case Laws     Income Tax     AT

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 have any relevance. Associated Enterprises have made the borrowing in foreign jurisdiction, therefore, the cost of borrowing of the assessee in India cannot be held to be an internal CUP. - order of the ld. AO to charge interest on the advances given to foreign associate enterprise at Libor plus 200 basis point confirmed - AT

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