https://www.taxtmi.com/caselaws?id=258800 The HC upheld the Tribunal's decision directing the AO to benchmark interest on a loan of EUR 20,50,000 advanced to an AE at the prevailing EURIBOR rate rather than the rupee loan rate, applying Section 92B. The court relied on prior Tribunal rulings in VVF Ltd. and Tech Mahindra Ltd., which held that ALP for loans to AEs should be based on the interest rate in the country where the loan is received or consumed. The revenue did not appeal those decisions and failed to justify a contrary stance in the present case. Consequently, the HC ruled against the revenue, affirming the Tribunal's approach to determining the arm's length interest rate. en-us Tue, 03 Feb 2015 00:00:00 +0530 Mon, 28 Jul 2025 10:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=258800 The HC upheld the Tribunal's decision directing the AO to benchmark interest on a loan of EUR 20,50,000 advanced to an AE at the prevailing EURIBOR rate rather than the rupee loan rate, applying Section 92B. The court relied on prior Tribunal rulings in VVF Ltd. and Tech Mahindra Ltd., which held that ALP for loans to AEs should be based on the interest rate in the country where the loan is received or consumed. The revenue did not appeal those decisions and failed to justify a contrary stance in the present case. Consequently, the HC ruled against the revenue, affirming the Tribunal's approach to determining the arm's length interest rate. Case-Laws Income Tax Tue, 03 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=258800