sales visàvis non AE sales.
x. Adjustment for interest free ECB loan
received from AE?
6. Brief facts of the case ... sale
price, and that the assessee has also
benefited from interest free ECB loans
from the AEs. None of these submissions
impressed
sales vis-a-vis Non AE sales.
e) Adjustment for interest free ECB Loan received from AE.
iv. In upholding the action ... sales vis-a-vis Non AE sales.
c) Adjustment for interest free ECB Loan received from AE.
iv. In upholding the action
cost by AE with 110% mark
up.
vi) Adjustment for interest free ECB Loan received from AE.
4. The short issue that we must begin ... sale price, and that the assessee has also benefited from interest free ECB loans
from the AEs. None of these submissions impressed
sales vis-a-vis Non AE sales.
v. Adjustment for interest free ECB Loan received from AE.
5. In the facts and circumstances ... sale price, and that the assessee has also benefited from
interest free ECB loans from the AEs. None of these submissions impressed
denominated ECB loan to
its wholly owned subsidiary company in India, viz. ADSIL. It was
observed by the A.O that the interest ... 4780/Mum/2015
the TPO the aforesaid interest free loan was treated as an
international transaction and the arms length price (ALP) of interest
require any adjudication.He also stated that assessee was interested in
pressing grounds no.2.1,3.1,3.2,4.1,5.1 and 5.2 only.Therefore ... Provision of marketing services 203,699,260 TNMM
2 Availing of Interest free ECB loan of 145,732,860 Nil ((Interest) -
3 Reimbursement of Expenses
upholding the transfer pricing adjustment in respect of USD denominated interest free ECB loan
ITA No.664/Mum/2017 ... regards the ALP of the interest
free advance that was granted by the assessee to its AE viz. ADSIL. On a perusal of the order
During the Financial Year 2016-17, the
Petitioner has advanced Interest Free ECB loan of
Rs.165,97,94,188/- to its subsidiary, an Indian ... undersigned, as reported in Insight
Portal, you have advanced interest free
ECB loan of Rs.165,97,94,188/- to an
Indian Company namely
learned DCI T erred by not allowing
corresponding deduction of the interest free loan granted by the appellant in the hands of
STNIPL.
6. Rate ... upholding the transfer pricing adjustment in respect of USD denominated interest free ECB loan
that was advanced by the assessee to its wholly owned subsidiary
Abacus Distribution Systems (India) ... vs Assessee on 21 November, 2013
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