Condonation of refiling delay refused where repeated defects, lack of diligence and vague explanations defeated the appeal against resolution plan app...
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TP adjustment - Benchmarking of interest on interest free advances good to the subsidiary companies - In the present case, the cost borrowing of the assessee does not have any relevance. Associated Enterprises have made the borrowing in foreign jurisdiction, therefore, the cost of borrowing of the assessee in India cannot be held to be an internal CUP. - order of the ld. AO to charge interest on the advances given to foreign associate enterprise at Libor plus 200 basis point confirmed - AT
TP adjustment - Benchmarking of interest on interest free advances good to the subsidiary companies - In the present case, the cost borrowing of the assessee does not have any relevance. Associated Enterprises have made the borrowing in foreign jurisdiction, therefore, the cost of borrowing of the assessee in India cannot be held to be an internal CUP. - order of the ld. AO to charge interest on the advances given to foreign associate enterprise at Libor plus 200 basis point confirmed - AT
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