LIBOR Rate more suitable for benchmarking loans/advances to associated enterprises in foreign currency

IBS Software Services Private Limited Vs ACIT (ITAT Cochin) ITAT Cochin held that since loans and advances are denominated in foreign currency, LIBOR Rates would be more suitable for benchmarking. Accordingly, AO directed to benchmark the international transaction of loan/advances to Associated Enterprise using applicable LIBOR Rate. Facts- The Assessee is a subsidiary of International Business Services Group (P) Limited having units in Software Technology Park of India and Special Economic Zone. During the assessment proceedings, it was noticed from the audit report in Form 3CEB that the Ass...