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M/S.Us Technology International P. ... vs The Acit,Cir-1(1),, Trivandrum on 11

average rate 6 of interest earned by the appellant instead of LIBOR / EURIBOR We shall adjudicate the issues ground-wise as under: Ground ... above submission, even if interest is to be considered LIBOR/EURIBOR should be considered. The same has been upheld in Salcomp Manufacturing India

NFAC and TPO has erred in applying rate of interest of 4.82% [LIBOR 0.32% + spread of 4.50%] as against 1.3% charged by the appellant ... fact that appellant itself has taken forex loan from Standard Chartered Bank @ LIBOR 0.99597% plus spread of 0.60%. As against this spread

overdue receivables, it has to be restricted at an interest rate of LIBOR as against SBI PLR rate." 5.1. We have heard both ... foreign currency (i.e., USD and GBP) and therefore, the LIBOR Rates for the said currencies should be considered as a suitable benchmark for determining

computed the interest on delayed receivables at LIBOR + 400 basis points and made an adjustment of Rs.83,46,909. The TPO also computed interest ... interest on a balance receivable from AE is to be adopted at LIBOR rate with suitable benchmarking. The DRP gave partial relief to the assessee

recovery of expenses at domestic borrowing rate of the Appellant instead of LIBOR/EURIBOR. Ground No 7-Erroneous TP adjustment on advances written ... charging interest at the rate of domestic borrowings instead of applying LIBOR rate on the recovery of expenses from the AE 14. In the present

levied a rate of interest of six months Libor plus 550 basic points on the outstanding receivables. The learned Counsel for the assessee argued that ... interest towards outstanding receivables. Alternatively it was submitted that six month LIBOR +200 2 ITA No.3/Coch/2024. D H Solutions India Private Limited

annum which is not an internal comparable uncontrolled price instead of using LIBOR. The Ld. DR relied on the order

against the interest rate outside India which was payable, i.e., LIBOR rate (London Interbank Offered Rate). It was because of this peculiar nature ... EXIM policy of the Government of India as well as lower LIBOR interest rate." [Emphasis Supplied] 4.6.12. Therefore, in the light of above decision

wrongly applied SBI PLR rate, whereas at the best only LIBOR could have been applied. Further, according to the ld AR, if the demand