Indian Kanoon - Search engine for Indian Law

Cummins India Limited, Pune vs Dy. Cit, Circle-1(1), Pune, Pune on 3 March

charged by the associated enterprise for the ECB with the interest rate LIBOR plus 2% prescribed by the RBI for ECB for the year ... against the interest rate of LIBOR plus 3% notified by RBI for the year 2003- 04, i.e. at the time when ECB Loan

application in this regard and further that an international rate like LIBOR or EURIBOR would come into play as the loan in question was denominated ... interest and noted in para 104 of his order that the average LIBOR rate as per the decision rendered by the Tribunal in another case

enterprises by determining its arm's length rate of interest at LIBOR + 5% instead of LIBOR + 0.875%. 3.2 On the facts and in circumstances ... interest on loan advanced in foreign jurisdiction on the basis of LIBOR plus basis. The market / country in which such loan is to be raised

annum. As per the TPO, the rate prevailing as per LIBOR +, for the year ending 31.03.2008 was 6.79%. The TPO tabulated the transactions of granting ... ending 31.03.2008 per the financials) [B] Base charge adopted by the assessee LIBOR [C] Base charge adopted by the assessee However, rate charged to benchmark

financing the European business acquisition and the said loan was raised @ interest LIBOR + 1.5% p.a. which ranges between 2 - 2.5% and the balance funds ... charged @ 4.75% p.a. However, the rate prevailing as per six months LIBOR + 1.5% for the year ending 31.03.2008 was 6.79%. The TPO tabulated

assessee had borrowed loan from City Bank and advanced the same on LIBOR+ rates to its associate enterprises, then the said transaction with its associate ... financing the European business acquisition and the said loan was raised @ interest LIBOR + 1.5% p.a. which ranges between 2 - 2.5% and the balance funds

borrowals of loans, which in turn, were advanced at LIBOR + rate to the associate enterprises, in case the advancement of loan to the associate enterprises ... LIBOR+ / WIBOR+ rates, then the said transaction with the associate enterprises is within arm's length price, otherwise, the TPO may re-compute

erred in law and on facts in applying interest @ LIBOR + 5% on the loan advanced to the AE party. 2. The learned ... order to benchmark the said transactions. The DRP however, applied interest @ LIBOR+5% on the loans advanced to associated enterprises. The Tribunal in earlier years

Length rate of interest at 8% on the basis of LIBOR plus certain basis points and made transfer pricing adjustment for the remaining interest equivalent