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