https://www.taxtmi.com/caselaws?id=306140 The Hon'ble Bombay High Court upheld the Tribunal's decision to apply LIBOR + 2% interest rate on monthly closing balances of advances to overseas Subsidiaries/Associated Enterprises, dismissing the Revenue's appeal. The Court affirmed that loans to AEs are international transactions subject to Arm's Length Price regulations, with interest at LIBOR + 2% considered arm's length. The Tribunal's consistent approach in previous rulings and the absence of comparable transactions led to the rejection of the TPO's benchmarking rate. The classification of loans as short-term working capital and the deletion of TPO's adjustment were supported, emphasizing the application of LIBOR + 2% for determining interest rates. en-us Thu, 25 Feb 2021 00:00:00 +0530 Thu, 12 Jan 2023 21:07:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306140 The Hon'ble Bombay High Court upheld the Tribunal's decision to apply LIBOR + 2% interest rate on monthly closing balances of advances to overseas Subsidiaries/Associated Enterprises, dismissing the Revenue's appeal. The Court affirmed that loans to AEs are international transactions subject to Arm's Length Price regulations, with interest at LIBOR + 2% considered arm's length. The Tribunal's consistent approach in previous rulings and the absence of comparable transactions led to the rejection of the TPO's benchmarking rate. The classification of loans as short-term working capital and the deletion of TPO's adjustment were supported, emphasizing the application of LIBOR + 2% for determining interest rates. Case-Laws Income Tax Thu, 25 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306140