interest in
respect of realization from AE based at UK shall be LIBOR instead of
PLR/Profit margin taken by the TPO. Since the realization ... from the AE
and in the foreign currency, therefore, the LIBOR would be the
appropriate comparable arm's length rate. Hence, by considering
imputing an interest of INR
96,03,898/- based on 6 months LIBOR plus a mark-up of 400 basis points. In
doing ... mark up of 400 basis points over and
above the 6 months LIBOR for calculating the rate of interest;
b) not giving benefit of early
imputing an interest of INR
96,03,898/- based on 6 months LIBOR plus a mark-up of 400 basis points. In
doing ... mark up of 400 basis points over and
above the 6 months LIBOR for calculating the rate of interest;
b) not giving benefit of early
assessee has been worked at 7.80%
which is based on LIBOR and it was submitted that to benchmark the
interest rate, actual cost of borrowing ... requested that the calculation of
interest should be based on the LIBOR based rate
addition
made on account of notional interest, the ld. CIT(A) applied LIBOR as
against the PLR applied by the TPO and then worked ... therefore, instead of applying the PLR as arm's length interest
LIBOR shall be considered as arm's length interest. Moreover
Chambal Fertilisers & Chemicals Ltd., ... vs Jcit, Kota on 31 January, 2018
vk;dj vihyh
length interest is to be considered by taking the LIBOR instead of PLR. The ld.
CIT (A) has considered this issue in para ... Rule 2 and 3 of the Income Tax Rules. The application
of LIBOR rate of interest was upheld by Hon'ble Delhi Tribunal
Global Ltd. vs. ACIT
however restricted the rate of interest to prevailing LIBOR rate plus 2%
and the relevant findings of the Coordinate Bench ... benches of ITAT including this
Bench of ITAT has held that prevailing LIBOR rate with marginal
variation shall be the reasonable TP adjustment.
1. Aurionpro
interest of INR 2,35,21,457/- based
on 6 Months LIBOR plus a mark up of 400 basis
points. In doing ... mark up of 400 basis points over and above the 6
months LIBOR for calculating the rate of
interest.
23.2 not giving benefit of early
million for its Fertilizer Division for capitalization of revamp
project at Libor linked interest rate. Further, in respect of forward cover
transactions, two forward cover
