Intra-bank transactions cannot always be rated at LIBOR

Shinhan Bank Vs DCIT (ITAT Mumbai)

ITAT Mumbai held that London Inter-Bank Offered Rate (LIBOR) cannot always be the rate at which intra-bank transactions must take place.

Facts- Assessee alleges that the Dispute Resolution Panel (DRP) has erred in upholding the action of the learned Deputy Commissioner of Income-tax (Transfer Pricing) (‘TPO’) in computing the arm’s length price of interest paid on foreign currency borrowings by the Appellant from its associated ente

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