https://www.taxtmi.com/caselaws?id=460911 ITAT Mumbai upheld reopening of assessment based on survey proceedings, rejecting assessee's challenge. For TP adjustment on interest-free loan to Italian AE, tribunal held that commercial expediency is irrelevant and loan must be benchmarked at arm's length price under Section 92. Assessee's claim of strategic shareholder function failed as loan was written off as irrecoverable. However, tribunal accepted assessee's alternative submission to charge interest at LIBOR+200 bps instead of Indian bank lending rates, following jurisdictional HC precedents. Additional ground regarding adhoc computation was dismissed due to lack of benchmarking details from assessee. en-us Mon, 06 Jan 2020 00:00:00 +0530 Sat, 01 Mar 2025 14:25:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460911 ITAT Mumbai upheld reopening of assessment based on survey proceedings, rejecting assessee's challenge. For TP adjustment on interest-free loan to Italian AE, tribunal held that commercial expediency is irrelevant and loan must be benchmarked at arm's length price under Section 92. Assessee's claim of strategic shareholder function failed as loan was written off as irrecoverable. However, tribunal accepted assessee's alternative submission to charge interest at LIBOR+200 bps instead of Indian bank lending rates, following jurisdictional HC precedents. Additional ground regarding adhoc computation was dismissed due to lack of benchmarking details from assessee. Case-Laws Income Tax Mon, 06 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460911