TP Adjustment - Interest on loans and advances given to the AEs ...

Case Laws Income Tax

May 9, 2023

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 and, therefore, domestic interest rate should not be applied for determining the interest rate in case of loans to be re-paid in foreign currency. - the ALP of interest shall be determined with reference to the interest rates applicable to the currency in which the loan has to be repaid. - AT

View Source

← Previous Next →

TP Adjustment - Interest on loans and advances given to the AEs ...

Case Laws Income Tax

May 9, 2023

You may also like:

TP Adjustment - Notional interest - interest-free advances extended by the assessee to its AE - In an uncontrolled condition and between persons other than associated...

TP adjustment of interest - CIT(A) confirmed upward adjustment towards interest by adopting rupee loan rate instead of LIBOR linked rate in respect of foreign currency...

TP adjustment on interest on advances given to AEs - LIBOR + 260 basis points - the transactions of loans advanced to AEs by the assessee was adequately demonstrated by...

TP Adjustment - associated enterprises (AEs) - Business advances cannot be construed as loan advanced to the assessee company. Once the same is excluded and the loans...

TP Adjustment - Interest on interest outstanding/interest receivable - The interest on a loan is a compensation received towards the utilisation of funds given by the...

TP Adjustment - rate of interest on loan availed from AE - when the prime lending rate itself had increased over the years and stood at 14.55% for the relevant period,...

TP adjustment - notional interest - short term advances made by the assessee to its associated enterprises - The assessee being unable to establish with evidence the...

TP Adjustment - Benchmarking of interest receivable on loan - when the assessee has charged higher interest on loan to subsidiary compared to the prevailing interest...

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

TP Adjustment - Addition considering the interest free loan and advances to its Associated Enterprises - As assessee got such huge business from its associated...

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

Disallowance of interest on the advance - Simply because the assessee has secured loan from Standard Chartered Bank that does not mean that same interest bearing fund...

TP Adjustment - arm’s length price of interest on short term loan granted to the AE - The fact that the assessee has provided a short term loan only for a period of 15...

TP Adjustment on notional interest on advances - The assessee being unable to demonstrate that the advances were not in the nature of loan/advance but were quasi capital...

Addition of interest attributable on the diversion of loan fund - Once own fund of the assessee exceeds the amount of interest free loans and advances, then a...

Quick Updates: