Trianz Holdings Private Limited , Bangalore Deputy Commissioner of Income Tax Circle-7(1)(1), Bangalore

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Last updated: 10 December 2020
Quick Summary
This case involves Trianz Holdings Private Limited appealing a transfer pricing adjustment made by the TPO. The assessee charged 8.28% interest on a loan to an associated enterprise, while the TPO proposed an adjustment based on a 14.47% interest rate. The tribunal has remitted the issue back to the AO/TPO for a fresh examination of the appropriate interest rate, considering the LIBOR rate and the specific transaction.

Court :
ITAT Bangalore

Brief :
This appeal is by the assessee directed against the final Assessment Order dated 31.01.2017. The first ground is with regard to Transfer Pricing Adjustment of Rs.1,50,63,720/-. The facts are that assessee charged interest at 8.28% on the loan given to Associated Enterprise (AE). However, the TPO charged interest at 14.47% to determine the TP adjustment on this issue. On the other hand, DR submitted that libor interest is to be charged.

Citation :
IT(TP)A No.699/Bang/2017

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1 Year PLAN
1999
(Excl. of GST ₹359)

2 Years PLAN
3499
(Excl. of GST ₹629)

BEST VALUE
3 Years PLAN
4999
(Excl. of GST ₹899)

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