Rate at which loan taken by Appellant cannot be taken as internal CUP to benchmark loan given to AE

LTIMindtree Limited Vs ACIT (ITAT Mumbai) ITAT Mumbai held that TPO was correct in concluding that the rate at which loan is taken by the Appellant cannot be taken as internal CUP to benchmark the loan given by the Appellant to its AE as there is a difference in credit rating of the Appellant and its AE. Facts- The case of the Appellant was selected for scrutiny and notice under Section 143(2) of the Act was issued. During the assessment proceedings, AO noted that the Appellant has entered into the international transactions with its Associated Enterprises (AEs) and therefore, reference was ma...