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    <title>2021 (6) TMI 330 - ITAT DELHI</title>
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    <description>The Tribunal allowed the appeal, directing the deletion of the adjustment on the interest received on the loan to the German subsidiary. The decision was based on the finding that the interest rate charged was higher than prevailing rates in Germany, aligning with the Comparable Uncontrolled Price method and the absence of credit risk due to the appellant being a holding company. The Tribunal&#039;s ruling favored the appellant in the benchmarking of interest receivable on the loan given to the subsidiary company in Germany, citing relevant case law to support its decision.</description>
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      <description>The Tribunal allowed the appeal, directing the deletion of the adjustment on the interest received on the loan to the German subsidiary. The decision was based on the finding that the interest rate charged was higher than prevailing rates in Germany, aligning with the Comparable Uncontrolled Price method and the absence of credit risk due to the appellant being a holding company. The Tribunal&#039;s ruling favored the appellant in the benchmarking of interest receivable on the loan given to the subsidiary company in Germany, citing relevant case law to support its decision.</description>
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