2021 (5) TMI 1011

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....OUNTANT MEMBER For the Assessee : Shri Prashant Meharchandani, AR For the Revenue : Shri R.Dipak, DR ORDER PER S.S. GODARA, J.M. : This assessee's appeal for AY.2012-13 arises against the ITO, Ward-16(3), Hyderabad's assessment dated 20-12-2016 framed in furtherance to the Dispute Resolution Panel ('DRP')- 1, Bengaluru's directions dt.25-10-2016 in F.No.148/DRP-1/ BNG/2016-17, invol....

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....is not liable to be sustained for the sole reason that the same has been made not as per LIBOR rate applicable in case of international loans but after taking State Bank of India's prime lending rate @14.75% in the Transfer Pricing Officer's (TPO) order and upheld to that @ 4% to 9.25% as applicable in case of the very bank's domestic short term deposits involving 7 - 554 days; as the case may be.....

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....ssessee's former substantive ground stands accepted in the above terms. 3. The assessee's next argument is that such interest on receivables ought not to have been treated as an international transaction covered under Explanation(c) to Section 92B of the Act, inserted in the Act vide Finance Act, 2012 w.e.f.01-04- 2001 is rejected as per the hon'ble Madras high court's decision in Redington....