Arm’s length interest rate computable based on market determined rate applicable to currency in which loan is repayable

Adani Power Ltd. Vs DCIT (ITAT Ahmedabad) ITAT Ahmedabad held that arm’s length interest rate for loan advanced to foreign subsidiary by Indian company should be computed based on market determined interest rate applicable to currency in which loan has to be repaid. Facts- Assessee M/s Adani Power Ltd has contributed a sum of Rs. 1,35,42,00,000/- to M/s Adani Power Pte Ltd and a sum of Rs. 2,89,30,91,520/- to M/s Adani Shipping Pte Ltd, both being Associated Enterprises of the assessee. Assessee was of the view that the sums advanced by the assessee company to its AEs were in the nature ...