Interest free loans extended as quasi capital to 100% subsidiary cannot have nil ALP

Brief of the case: In this case ITAT examined that whether Arm’s Length Price (ALP) adjustments will also be warranted in case of interest free loans extended as quasi capital and what are the connotations of expression ‘quasi capital’ in the context of the transfer pricing legislation. After considering the facts and circumstances of the matter ITAT decided the issue against the assessee and confirmed the view taken by AO & CIT (A) by observing that the assessee has not offered any assistance on the quantum of ALP adjustment in respect of loan transaction, and that in the subsequent...