TP- Unrelated Internal comparable supersede External comparable

Brief of the Case

I.T.A No. 1292/Bang/2010

ITAT Bangalore held in the case of M/s. Intergarden (India) P. Ltd. vs. ACIT that Revenue has not disputed the fact that effective rate of interest paid by assessee in India was 6.62% on loans whereas  Interest paid by assessee on loans taken from AE abroad was 5%. This was below the rate of interest assessee was paying on loans taken within India. When internal CUP with unrelated parties is available, it sh

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