ITAT Mumbai Upholds 6.5% Fixed Interest Benchmark on AE Loans Due to Long-Term Non-Payment

JSW Energy Limited Vs ACIT (ITAT Mumbai) In JSW Energy Limited Vs ACIT, the ITAT Mumbai dealt with transfer pricing adjustments relating to interest on loans advanced to Associated Enterprises (AEs), deduction under Section 80-IA, and benchmarking of power supplied to AEs. The assessee, engaged in the business of power generation and operation of power plants, had entered into international and specified domestic transactions with its AEs. During assessment proceedings, the Transfer Pricing Officer (TPO) made an upward adjustment of ₹14.57 crore relating to interest on loans advanced to its ...