https://www.taxtmi.com/caselaws?id=342039 The Tribunal upheld the applicability of transfer pricing provisions to the transactions with the subsidiary. It confirmed the addition of Rs. 3,34,28,873/- as Arm's Length Price of loan interest, rejecting the argument of quasi-capital treatment. The Tribunal allowed the adoption of LIBOR+2% for the Arm's Length Price adjustment, overturning the 8.7% rate decision. It dismissed the disallowance under Section 35D and treated the forex derivative loss as a business loss. The non-allowance of exchange rate fluctuation loss was not pressed and dismissed. The appeal was partly allowed in favor of the assessee on specific issues. en-us Tue, 11 Apr 2017 00:00:00 +0530 Sun, 23 Apr 2017 07:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=342039 The Tribunal upheld the applicability of transfer pricing provisions to the transactions with the subsidiary. It confirmed the addition of Rs. 3,34,28,873/- as Arm's Length Price of loan interest, rejecting the argument of quasi-capital treatment. The Tribunal allowed the adoption of LIBOR+2% for the Arm's Length Price adjustment, overturning the 8.7% rate decision. It dismissed the disallowance under Section 35D and treated the forex derivative loss as a business loss. The non-allowance of exchange rate fluctuation loss was not pressed and dismissed. The appeal was partly allowed in favor of the assessee on specific issues. Case-Laws Income Tax Tue, 11 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=342039