https://www.taxtmi.com/caselaws?id=234349 The ITAT Delhi held that the interest rate of 4% charged by the assessee on a foreign currency loan to its subsidiary was at arm's length, rejecting the DRP's adjustment to 13.25%. The tribunal applied the CUP method and ruled that LIBOR, not domestic prime lending rates, is the appropriate benchmark for international loans in foreign currency. Since the assessee's loan arrangement with a bank was below 4%, the charged rate was reasonable. The tribunal also noted the assessee's profits were exempt under section 10B, negating concerns of profit shifting. Consequently, the transfer pricing adjustment suggested by the TPO was unwarranted, and the assessee's appeal was allowed. en-us Fri, 08 Feb 2013 00:00:00 +0530 Mon, 04 Aug 2025 17:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=234349 The ITAT Delhi held that the interest rate of 4% charged by the assessee on a foreign currency loan to its subsidiary was at arm's length, rejecting the DRP's adjustment to 13.25%. The tribunal applied the CUP method and ruled that LIBOR, not domestic prime lending rates, is the appropriate benchmark for international loans in foreign currency. Since the assessee's loan arrangement with a bank was below 4%, the charged rate was reasonable. The tribunal also noted the assessee's profits were exempt under section 10B, negating concerns of profit shifting. Consequently, the transfer pricing adjustment suggested by the TPO was unwarranted, and the assessee's appeal was allowed. Case-Laws Income Tax Fri, 08 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=234349