https://www.taxtmi.com/caselaws?id=306452 The Tribunal partially allowed the appeal by M/s Aithent Technologies Pvt. Ltd., directing the Transfer Pricing Officer to recalculate notional interest at US LIBOR plus 170 basis points for loans to its wholly owned subsidiary. The decision, issued on 2nd September 2019, addressed the adjustments made by tax authorities regarding notional interest, Arm's Length Price determination, and the application of LIBOR rates in transfer pricing analysis. The Tribunal accepted a reduced mark-up, emphasizing the specific circumstances of the case and the justifiability of the mark-up. en-us Mon, 02 Sep 2019 00:00:00 +0530 Tue, 31 Jan 2023 21:07:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306452 The Tribunal partially allowed the appeal by M/s Aithent Technologies Pvt. Ltd., directing the Transfer Pricing Officer to recalculate notional interest at US LIBOR plus 170 basis points for loans to its wholly owned subsidiary. The decision, issued on 2nd September 2019, addressed the adjustments made by tax authorities regarding notional interest, Arm's Length Price determination, and the application of LIBOR rates in transfer pricing analysis. The Tribunal accepted a reduced mark-up, emphasizing the specific circumstances of the case and the justifiability of the mark-up. Case-Laws Income Tax Mon, 02 Sep 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306452