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Transfer Pricing Adjustment Softened for Long-Standing ECB Loans
Case Law Details
- Case Name
- Gulbrandsen Technologies (India) Private Limited Vs Additional/Joint/Deputy/ACIT/ITO-National Faceless Assessment Centre (ITAT Ahmedabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2017-18
- Courts
- All ITAT, ITAT Ahmedabad
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Gulbrandsen Technologies (India) Private Limited Vs Additional/Joint/Deputy /ACIT/ITO-National Faceless Assessment Centre (ITAT Ahmedabad)
Fixed ECB Rate Accepted: ITAT Ahmedabad Resolves Transfer Pricing Dispute by Benchmarking at 5.35%
ITAT Ahmedabad “D” Bench, in Gulbrandsen Technologies (India) Pvt. Ltd. vs ACIT (NFAC) (ITA No. 160/Ahd/2022, AY 2017-18, order dated 23-12-2025), dealt with a transfer pricing adjustment on interest paid on ECB loans obtained from Associated Enterprises.
The assessee had availed ECB in FY 2005-06 at a fixed interest rate of 5.50%, duly approved by RBI and...
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