https://www.taxtmi.com/caselaws?id=239629 ITAT Mumbai held that interest-free loans advanced by the assessee to wholly owned subsidiaries constitute international transactions under section 92B and are subject to transfer pricing regulations. The comparable uncontrolled price (CUP) method is appropriate for determining the arm's length price (ALP) of interest on such loans. The Tribunal accepted LIBOR plus a margin as the benchmark rate, overruling the assessee's contention that no adjustment was needed due to commercial considerations. While the TPO applied LIBOR plus 3%, the Tribunal directed adoption of LIBOR plus 2% as the arm's length interest rate on the monthly closing balance of advances. The appeal was partly allowed, remanding for recalculation accordingly. en-us Fri, 12 Apr 2013 00:00:00 +0530 Tue, 05 Aug 2025 15:01:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239629 ITAT Mumbai held that interest-free loans advanced by the assessee to wholly owned subsidiaries constitute international transactions under section 92B and are subject to transfer pricing regulations. The comparable uncontrolled price (CUP) method is appropriate for determining the arm's length price (ALP) of interest on such loans. The Tribunal accepted LIBOR plus a margin as the benchmark rate, overruling the assessee's contention that no adjustment was needed due to commercial considerations. While the TPO applied LIBOR plus 3%, the Tribunal directed adoption of LIBOR plus 2% as the arm's length interest rate on the monthly closing balance of advances. The appeal was partly allowed, remanding for recalculation accordingly. Case-Laws Income Tax Fri, 12 Apr 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239629