https://www.taxtmi.com/caselaws?id=207974 ITAT, Mumbai - AT held that the internal CUP - the rate of foreign-currency borrowings from the bank - is an appropriate arms-length interest rate for interest-free loans advanced to wholly owned foreign subsidiaries, and directed the AO to recompute the ALP accordingly; the fact that the bank loan was not specifically used to fund the remittances was held immaterial. The Tribunal also remanded the claim for deduction under s.80HHC for fresh computation by the AO in accordance with the retrospective amendment to that provision. en-us Fri, 08 Jan 2010 00:00:00 +0530 Wed, 03 Jun 2026 15:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207974 ITAT, Mumbai - AT held that the internal CUP - the rate of foreign-currency borrowings from the bank - is an appropriate arms-length interest rate for interest-free loans advanced to wholly owned foreign subsidiaries, and directed the AO to recompute the ALP accordingly; the fact that the bank loan was not specifically used to fund the remittances was held immaterial. The Tribunal also remanded the claim for deduction under s.80HHC for fresh computation by the AO in accordance with the retrospective amendment to that provision. Case-Laws Income Tax Fri, 08 Jan 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207974