Indian Kanoon - Search engine for Indian Law

income attributable to the assessee. Therefore, instead of the US rate or LIBOR, it will

charged the rate of interest is to be restricted to LIBOR / LIBOR + 200 bps. 14. On the facts and in the circumstances of the case ... restricting the rate of interest on the loan transaction to LIBOR rates without any spread. 15. Without prejudice, learned TPO/ learned

ITAT was right in adopting "LIBOR" (London. Inter Bank Offered Rate) as benchmark for interest on loan given to associate enterprises from India ... ITAT erred in directing the AO/TPO to adopt the LIBOR rate plus 2% as the rate of interest, for making adjustment to ALP, without

subsidiary Company should be worked out at a rate of interest at LIBOR plus 200 basis points as against interest at LIBOR plus 100 basis ... subsidiary Company and the prevailing rate of interest under CUP Method was LIBOR plus 100 basis points as the Appellant Company itself has availed

DCIT/DRP erred in law by using prime lending rate instead of LIBOR for determining the arm's length interest amount. 5.6 The learned ... free loan given by the assessee to its AE, viz. ADSIL the LIBOR rate prevailing as on 31.03.2012 should have been considered

that the SBI Hong Kong has granted loan to the AE at LIBOR plus 145 bps which ... None of these submissions, however, impressed the TPO. He proceeded to adopt LIBOR plus 445 bps as the arm's length price

against interest charged by the appellant at: (a) monthly LIBOR + 150 bps for loan of US$ 3,00,000/- given ... months LIBOR plus 230 bps to MSACC On the facts and circumstances of the case and in law, the interest charged by the appellant

Rate ('PLR') rather than London Inter-Bank Offered Rate ('LIBOR') rate. 5 ITA No. 2314/Hyd/2018 Adama India ... erred in upholding the action of Ld. TPO / Ld. AO in considering LIBOR plus 200 basis points as an arm's length interest

adjustment can exceed an arm‟s length price adjustment based on the LIBOR simpliciter. Grounds of appeal nos. 1 to 6 deal with these issues ... loan, however, the Panel directed the AO to apply interest rate of LIBOR + 3% as ITA No. 6331/Mum/2019 Assessment year 2014-15 Page

international transaction in foreign currency has to be in accordance with LIBOR/EURIBOR. 10. On the facts and in the circumstances of the case ... International PTE Limited (for short „IIPL‟) at an interest rate of USD LIBOR plus 5.5%. Further, loan was given by the assessee in EUROS