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 enterprise (AEs’) by applying London Inter-Bank Offered Rate (LIBOR). Notably, the grievances pertain to ALP adjustments in r...