Thursday, 11 December 2014

No TP adjustment for interest earned by foreign branch from ECB which is subject to credit analysis

IT/ILT: Where assessee Indian branch of foreign bank made credit analysis of Indian borrowers which helped overseas branch for taking decisions on granting loans to Indian borrowers, no part of income of interest paid by Indian borrower could be attributed to assessee in respect of fees received by it for purpose of transfer pricing adjustment


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