If there is International transaction, Arm’s Length Price would be decided using international commercial principle.

Brief Summary The assessee, respondent, an Indian company having head quarter located in Delhi, was engaged in the business of manufacture and exports of rider apparels. It had incorporated its wholly owned subsidiary company named M/s JPC Equestrian for the purpose of marketing and promotion of their exports to USA. The respondent assessee has granted loan of USD 1050000 at interest rate of 4% which was derived using ‘Comparable Uncontrolled Price Method’, to its subsidiary company M/s JPC Equestrian (hereinafter termed as Associate Enterprise as per Income Tax Act). The Transfer Pricing ...