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ITAT addressed transfer pricing adjustment concerning interest rate on loan extended by assessee to associated enterprise in Dubai at 1-year LIBOR plus 2.5% totaling 3.8% annually. Primary legal issue involved determining appropriate benchmark interest rate - whether Indian prevailing rates should apply given lender's Indian residence, or USD lending rates considering Dubai borrower's location. ITAT relied on Cotton Nature India precedent establishing that loan repayment currency determines applicable rate of return. Since record lacked clarity regarding agreed repayment currency, ITAT directed assessee to furnish supporting documentation establishing repayment currency terms. Based on such evidence, Assessing Officer and Transfer Pricing Officer must reconsider appropriate interest computation methodology for arms length pricing determination.
ITAT addressed transfer pricing adjustment concerning interest rate on loan extended by assessee to associated enterprise in Dubai at 1-year LIBOR plus 2.5% totaling 3.8% annually. Primary legal issue involved determining appropriate benchmark interest rate - whether Indian prevailing rates should apply given lender's Indian residence, or USD lending rates considering Dubai borrower's location. ITAT relied on Cotton Nature India precedent establishing that loan repayment currency determines applicable rate of return. Since record lacked clarity regarding agreed repayment currency, ITAT directed assessee to furnish supporting documentation establishing repayment currency terms. Based on such evidence, Assessing Officer and Transfer Pricing Officer must reconsider appropriate interest computation methodology for arms length pricing determination.
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