Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
ITAT determined that for benchmarking outstanding receivables from Associated Enterprises (AEs), the applicable interest rate should be LIBOR, not domestic prime lending rates. The tribunal found the average LIBOR rate for 1-4-2005 to 31-3-2006 was 4.42%, and since the assessee charged 6% interest, which exceeded LIBOR, no additional transfer pricing adjustment was warranted. The decision emphasized that international transactions with AEs must be evaluated using international benchmark rates like LIBOR or EURIBOR, rather than domestic lending rates, ensuring arm's length pricing principles are consistently applied in cross-border financial transactions.
ITAT determined that for benchmarking outstanding receivables from Associated Enterprises (AEs), the applicable interest rate should be LIBOR, not domestic prime lending rates. The tribunal found the average LIBOR rate for 1-4-2005 to 31-3-2006 was 4.42%, and since the assessee charged 6% interest, which exceeded LIBOR, no additional transfer pricing adjustment was warranted. The decision emphasized that international transactions with AEs must be evaluated using international benchmark rates like LIBOR or EURIBOR, rather than domestic lending rates, ensuring arm's length pricing principles are consistently applied in cross-border financial transactions.
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