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The ITAT remanded the matter to the TPO for a fresh transfer pricing examination concerning the interest rate on ECB loans from the AE, directing the application of the FAR analysis in selecting comparables. The tribunal noted the absence of such analysis in prior proceedings and acknowledged the assessee's RBI approvals for payments to the AE. It emphasized that the TPO must consider RBI-prescribed interest rates relevant for benchmarking commercial borrowings during the relevant period. Consequently, the assessee's appeal was allowed for statistical purposes, mandating a reassessment consistent with these guidelines.
The ITAT remanded the matter to the TPO for a fresh transfer pricing examination concerning the interest rate on ECB loans from the AE, directing the application of the FAR analysis in selecting comparables. The tribunal noted the absence of such analysis in prior proceedings and acknowledged the assessee's RBI approvals for payments to the AE. It emphasized that the TPO must consider RBI-prescribed interest rates relevant for benchmarking commercial borrowings during the relevant period. Consequently, the assessee's appeal was allowed for statistical purposes, mandating a reassessment consistent with these guidelines.
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