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The ITAT held that the taxpayer's benchmarking of interest on FCCDs payable to its AEs by applying the domestic PLR was justified; the matter is governed by the Special Bench decision favoring PLR over LIBOR, and the AO/TPO is directed to recompute the ALP accordingly. The Tribunal further held that rental receipts and allied service income from letting of commercial property constitute profits and gains of business or profession (not income from house property) where the taxpayer's activities align with letting as the main object, and directed recomputation of income under that head. Finally, the ITAT denied deduction under s.80IAB, finding the taxpayer was not a "developer" and therefore ineligible for s.80IAB relief (ground dismissed).
The ITAT held that the taxpayer's benchmarking of interest on FCCDs payable to its AEs by applying the domestic PLR was justified; the matter is governed by the Special Bench decision favoring PLR over LIBOR, and the AO/TPO is directed to recompute the ALP accordingly. The Tribunal further held that rental receipts and allied service income from letting of commercial property constitute profits and gains of business or profession (not income from house property) where the taxpayer's activities align with letting as the main object, and directed recomputation of income under that head. Finally, the ITAT denied deduction under s.80IAB, finding the taxpayer was not a "developer" and therefore ineligible for s.80IAB relief (ground dismissed).
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