accordingly, loan available in the international
market with interest rate computed considering Libor rates shall
be applied for benchmarking.
3.2 Without prejudice, the assessing officer ... accordingly, arm's length interest rate
shall be computed considering Libor rates applicable on foreign
denominated loans.
4.6 Without prejudice the assessing officer
nterest rate of L ondon Inter- Ban k Offer Rate ("LIBOR") pl us 2
percent pe r annum payabl e annuall ... agreed for an i nterest rate revi sion i n 2009 from LIBOR +200
bps to LIBOR + 350 bps based on Barcl ay bank
Dcit, New Delhi vs M/S. Ongc Videsh Ltd., New Delhi on 5 September, 2022
advanced to the AEs and imputing interest at the rate
equal to LIBOR plus 400 basis points;
2.2. disregarding the intercompany pricing arrangement ... interest is to be imputed, instead of an ad-hoc
rate of LIBOR plus 400 basis points, the LIBOR rate alone
Indian banks are charging interest rate of 2.5% to 5% above
LIBOR/EURIBOR for foreign currency loans" and, therefore ... view that interest rate of 4% above LIBOR would be reasonable for the loans of
BB rating for a period of five years
Addendum Agreement Dated 14.01.2011
for an annual interest rate of LIBOR + 300 bps to be paid
on the loan amount applicable from 14.04.2011 till ... contention of the assessee-company of
charging rate of interest as LIBOR + 300 bps on the
grounds that (i) assessee-company is a tested party
being
labor + 700 basis points, as against the rate of LIBOR +200 bps charged by the
appellant.
3.1 That the Commissioner of Income Tax (Appeals ... loan from financial institutions, viz., SBI,
at the rate of 3 months LIBOR + 170 basis points and from ICICI at 3 months LIBOR
+ 140 basis
earlier years
which remains unpaid, on a daily basis of six-month LIBOR rate
along with 400 basis point as the most appropriate comparable
uncontrolled ... year as comparable
transaction, where interest charged was at the rate of LIBOR plus
2%, i.e., 2.23 percentile. Thus, it was claimed that
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
submitted
that the assessee had provided loan to its AEs at LIBOR +1.1% to
Dabur UK and at 7% to Dabur Thailand. It was submitted ... been mentioned that the same loan could have
been taken at LIBOR +1.5% in the absence of corporate
guarantee and, thus, Dabur
