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TP adjustment on interest on advances given to AEs - LIBOR + 260 ...


Transfer Pricing Adjustment on AE Loan Interest Deemed Unwarranted; Arm's Length Price Proven with Comparability Analysis.

November 5, 2023

Case Laws     Income Tax     AT

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 the assessee to be at Arm’s Length Price based on the comparability analysis done with its internal comparable. No transfer pricing adjustment to the same was warranted and the transfer pricing adjustment made by the authorities below is directed to be deleted. - AT

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