2022 (6) TMI 656

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... : Shri B. S. Anand, Sr. D.R. ORDER PER ANIL CHATURVEDI, AM : This appeal filed by the Revenue is directed against the order dated 15.05.2018 of the Commissioner of Income Tax (Appeals)-29, New Delhi relating to Assessment Year 2015-16. 2. Brief facts of the case as culled out from the material on record are as under:- 3. Assessee is a company namely stated to be engaged in the busi....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....(P.) Ltd. (55 taxmann.com 523 Delhi High Court) as the case of the assessee pertains to interest on loan and its taxability and not on the issues raised in the judgement relied upon. Hence, SBI Market lending Rate will be applicable because money has been loaned from an Indian Rupee Account. 2. The Ld. CIT(A) has erred in deleting the addition on account of interest on loan to AE ignoring....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....why the interest not be calculated at arm's length as done in the previous assessments. The assessee filed the submissions which was not found acceptable to AO. AO thereafter on the basis of the interest charged by State Bank of India to foreign denominated loans, worked out the interest adjustment at LIBOR at 4.5% and accordingly worked out the interest adjustment of Rs.96,86,209/- on substantive....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ear under consideration are identical to that of earlier years, the grounds of Revenue needs to be dismissed. 7. Learned DR on the other hand supported the order of AO. 8. We have heard the rival submissions and perused the material available on record. The issue in the present ground is about the deletion of adjustment made on account of interest of loan on the amount advanced by the assess....