In case of Loan, bank rate of country of currency should be adopted for TP ALP calculation

DCIT Vs M/s. Russell Credit Limited (ITAT Kolkata)

Hon’ble High Court of Bombay in CIT Vs. the Great Eastern Shipping Co. Ltd. in ITA No. 1455 of 2014 dated 28.06.2017 has upheld the action of the Tribunal wherein it was held that arm’s length price in the case of loans advanced to AE would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. In the light of the aforesaid decisions of the Hon’ble Delhi High Court as well as Hon’ble Bombay High Court, the act

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