Sunday 18 January 2015

Interest paid to AE was at ALP if it was lower than rate of interest paid by AE to independent party

IT/ILT : Where loans taken by assessee from its AE were interest free for initial period of seven years and when said period of moratorium was taken into account, effective rate of interest incurred by assessee was lower than arm's length rate of interest considered by TPO, adjustment made to assessee's ALP on aforesaid ground was to be set aside


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