https://www.taxtmi.com/caselaws?id=336906 Transfer pricing on a loan to a subsidiary associated enterprise was treated as fact-dependent, with the Court stressing that LIBOR-linked comparables, the spread charged, and the loan terms must be examined case by case to test arm's-length pricing. It also held that observations suggesting advances to foreign subsidiaries are not automatically international transactions are not binding in general. On the Section 14A disallowance, the Court accepted the Tribunal's factual finding that exempt-income investments were funded from own funds, making Rule 8D inapplicable on those facts. In both matters, no substantial question of law arose and the Revenue's appeals failed. en-us Mon, 17 Oct 2016 00:00:00 +0530 Fri, 30 Dec 2016 18:14:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=336906 Transfer pricing on a loan to a subsidiary associated enterprise was treated as fact-dependent, with the Court stressing that LIBOR-linked comparables, the spread charged, and the loan terms must be examined case by case to test arm's-length pricing. It also held that observations suggesting advances to foreign subsidiaries are not automatically international transactions are not binding in general. On the Section 14A disallowance, the Court accepted the Tribunal's factual finding that exempt-income investments were funded from own funds, making Rule 8D inapplicable on those facts. In both matters, no substantial question of law arose and the Revenue's appeals failed. Case-Laws Income Tax Mon, 17 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=336906