Business advances also need to be benchmarked on Libor ALP

CLR Editorial Note: The assessee, an Indian company, had given loans of Rs. 15.65 crores to its Associated Enterprises s in USA, Singapore and Bahrain. In its assessment report, it claimed that the said loans were working capital advances given for commercial consideration to secure the business and that no interest was recoverable on it.… Read More

Tags: Arms Length PricingIndiaLIBORtransfer pricing

CUP & LIBOR most appropriate to determine ALP of Loan Transaction

CLR Editorial Notes: The case refers to a case of Transfer pricing on a loan transaction made by the assessee and the appellant in this case. The assessee was an Indian company which gave a loan of more than USD 1 Million to its USA based Associated Enterprise (AE) at a interest rate of 4%. The Transfer Pricing… Read More

Tags: ALPArm's length principleCitiBankCommonwealth Law ReportsIndiaLIBORPrime Lending RateTPOtransfer pricingUnited States

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