case, except that, in this assessment year and as
against LIBOR plus 2% adopted by the TPO himself as arm's length interest ... subsidiary was to obtain this loan from the bank, in addition to LIBOR plus 2%,
the assessee would have needed a guarantee from its parent
erred in upholding the addition of LIBOR + 1% on
account of notional interest charged on loans advanced to its
subsidiaries on the alleged ground that ... rate that was higher than the London Inter-Bank
Borrowing Rate ("LIBOR") and other international
benchmarking rates which is used as the international
erred in upholding the addition of LIBOR + 1% on
account of notional interest charged on loans advanced to its
subsidiaries on the alleged ground that ... rate that was higher than the London Inter-Bank
Borrowing Rate ("LIBOR") and other international
benchmarking rates which is used as the international
Pharmaceuticals Ltd
AY :2013-14 and 2014-15
basic points to the LIBOR/EURIOBOR spread towards forex risk
adjustment."
6. The issue raised ... rate of
3.22% - derived on the basis of LIBOR + 260 basis points. The assessee
had adopted the rate based on a quotation given
Pharmaceuticals Ltd
AY :2013-14 and 2014-15
basic points to the LIBOR/EURIOBOR spread towards forex risk
adjustment."
6. The issue raised ... rate of
3.22% - derived on the basis of LIBOR + 260 basis points. The assessee
had adopted the rate based on a quotation given
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
ignoring the findings of
the TPO and holding that LIBOR, rate should be applied on interest
advanced to Associate Enterprises in US and thereby deleting ... ignoring the
findings of the TPO and holding that LIBOR rate should be applied on
interest on receivables for excess period granted
loans to its AE which were
benchmarked by the assessee by applying LIBOR + 200 basis points as
the ALP rate. This was accepted ... loans to AE have been benchmarked by applying interest rate
of LIBOR + 200 basis points. Though this is a disclosure error in Form
No.3CEB
amount of USD 100 million at an
interest rate of LIBOR +325 basis points in order to refinance its existing loan
with Bank of India ... would have had to borrow funds at an interest rate of around LIBOR +387.5
basis points on a standalone basis. However, the assessee‟s guarantee
imputed, interest rate should be calculated
with reference to LIBOR only. The learned TPO rejected the
contention of the assessee and held that ... imputed the interest rate to be calculated with
reference to LIBOR rate. The TPO vide order dated 25-10-
2018, passed under section 92CA
