Interest charged at Rs.
Rua 14,25,759/- @ Libor plus
200 BPs
3. Torrent Pharma Short term finance Various Interest charged and
Philippines squared ... during amount benchmarked at Rs.
the year 12,62,288/- @ Libor +
100Bps
13.1. In response to SCN issued by TPO, assessee submitted that
being adjustment in respect of Interest
on Loan to Associated Enterprise applying LIBOR rate in the financial year in
which loan was granted plus ... assessee to its associated enterprises was
compared to the prevailing LIBOR at the time of granting such loan.
Accordingly, the assessee claimed the international transaction
proposing to make adjustment on account of interest on the loans
using LIBOR rate of 4.16% in respect of the Mauritius loan ... assessment years, the
assessee himself has accepted ALP adjustment by adopting the LIBOR + 2%
interest rate. In this view of the matter, no interference
Dcit, New Delhi vs M/S. Ongc Videsh Ltd., New Delhi on 5 September, 2022
income attributable to the assessee. Therefore, instead of the US rate or
LIBOR, it will
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
foreign subsidiaries in UK and Thailand and had
charged interest rate of LIBOR plus 1.1% and 7% respectively
whereas the TPO had applied the interest ... 2014 ITA
No.3495/Del/2014 LIBOR plus 1.1% and the loan taken by the UK
subsidiary from ABM AMRO Bank was at LIBOR
Jain, who appears for the petitioner, says that the interest @
1% plus LIBOR is charged only when remittance is made.
3. On the other hand ... that the
two transactions are different. According to them, interest @ 1%
plus LIBOR is charged as and when Packing Credit in Foreign
Currency (PCFC) facility
Dcit (It) 4(2)(1), Mumbai vs Shinhan Bank, Mumbai on 9 November, 2022
ITA
proposing to benchmark the interest rate
on Fully Compulsory Convertible Debentures at LIBOR+200 basis
points ignoring that the Fully Compulsory Convertible debentures
were denominated ... benchmarked the interest rate paid by the assessee by
taking the Libor Plus 200 basic points. Paras 7.2 to 7.4 of
the TPO order
