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    <title>2015 (3) TMI 1031 - DELHI HIGH COURT</title>
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    <description>HC held for the assessee that the arm&#039;s-length interest rate must reflect the market rate for the currency in which the loan is denominated and repaid; where the loan was in US$, the relevant comparable are dollar-denominated rates, not domestic PLR or rupee rates. ITAT&#039;s finding that 4% p.a. charged by the taxpayer to its associated enterprise was arm&#039;s length was upheld and the assessment adjustment to 12.20% was unwarranted. The court endorsed a currency-specific approach to determine interest in transfer pricing.</description>
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    <pubDate>Fri, 27 Mar 2015 00:00:00 +0530</pubDate>
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      <title>2015 (3) TMI 1031 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=258097</link>
      <description>HC held for the assessee that the arm&#039;s-length interest rate must reflect the market rate for the currency in which the loan is denominated and repaid; where the loan was in US$, the relevant comparable are dollar-denominated rates, not domestic PLR or rupee rates. ITAT&#039;s finding that 4% p.a. charged by the taxpayer to its associated enterprise was arm&#039;s length was upheld and the assessment adjustment to 12.20% was unwarranted. The court endorsed a currency-specific approach to determine interest in transfer pricing.</description>
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      <pubDate>Fri, 27 Mar 2015 00:00:00 +0530</pubDate>
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