https://www.taxtmi.com/caselaws?id=365720 An interest-free advance to an associated enterprise may still attract arm's length interest under transfer pricing principles, and an Article 11 treaty argument was treated as inapplicable because the dispute concerned a section 92 adjustment rather than taxation of actually paid interest. For benchmarking a foreign currency loan repayable in the same currency, the comparable rate should reflect that currency's market rate, so LIBOR was preferred over SBI Prime Lending Rate. The transfer pricing addition was therefore sustained in principle, while recomputation was directed using LIBOR, giving the assessee only partial relief. en-us Fri, 03 Aug 2018 00:00:00 +0530 Wed, 22 Aug 2018 08:06:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=365720 An interest-free advance to an associated enterprise may still attract arm's length interest under transfer pricing principles, and an Article 11 treaty argument was treated as inapplicable because the dispute concerned a section 92 adjustment rather than taxation of actually paid interest. For benchmarking a foreign currency loan repayable in the same currency, the comparable rate should reflect that currency's market rate, so LIBOR was preferred over SBI Prime Lending Rate. The transfer pricing addition was therefore sustained in principle, while recomputation was directed using LIBOR, giving the assessee only partial relief. Case-Laws Income Tax Fri, 03 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=365720