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: ALP, Arm's length principle, CitiBank, Commonwealth Law Reports, India, LIBOR, Prime Lending Rate, TPO, transfer pricing, United States