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Court Rules 13.5% Loan Interest from Associated Enterprise Comparable to 14.55% Prime Rate in Transfer Pricing Case.
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....TP Adjustment - rate of interest on loan availed from AE - when the prime lending rate itself had increased over the years and stood at 14.55% for the relevant period, the comparable rate of interest could not be considered at erstwhile rates in a dynamic interest rate environment. Hence, the interest rate of 13.5% paid by the assessee to its AEs being comparable to the prevailing PLR cannot be said to be excessive. - AT....