Direction for Determination of US LIBOR
Last updated: 11 January 2021
Court :
ITAT New Delhi
Brief :
The present appeal has been fi led by the assessee againstthe order dated 31.07.2017 passed by the AO u/s 254/143(3)r.w.s. 144C of the Income Tax Act, 1961.
Citation :
ITA No. 6293/Del/2017
IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH ‘I-1’, NEW DELHI
Before Sh. H. S. Sidhu, Judicial Member
Dr. B. R. R. Kumar, Accountant Member
(Through Video Conferencing)
ITA No. 6293/Del/2017 : Asstt. Year : 2005-06
Aithent Technologies Pvt. Ltd.,
A-16/9, Vasant Vihar,
New Delhi-110057
(APPELLANT)
PAN No. AAACS2319H
Vs
DCIT,
Circle-2(1),
New Delhi-110002
(RESPONDENT)
Assessee by : Sh. Atul Ninawat, AR
Revenue by : Sh. Surender Pal, CIT DR.
Date of Hearing: 14.12.2020
Date of Pronouncement: 05.01.2021
ORDER
Per Dr. B.R.R. Kumar, Accountant Member:
The present appeal has been fi led by the assessee againstthe order dated 31.07.2017 passed by the AO u/s 254/143(3)r.w.s. 144C of the Income Tax Act, 1961.
2. Fol lowing grounds have been raised by the assessee:
“1. The order of the learned Assessing Of ficer (‘Ld.AO’) is bad in law and on the facts and circumstances of the case.
2. The Ld. Transfer Pricing Of ficer (‘Ld. TPO’)/ Ld. Assessing Officer (‘Ld. AO’) have erred on facts andcircumstances of the case in determining the arm’slength price of the appel lant’s internationaltransaction with its associated enterprises in respectof interest on loan advanced to whol ly ownedsubsidiary thereby proposing an enhancement of returned income by Rs.1,47,99,068/-.
3. The Ld. TPO/AP/Ho’ble DRP has erred in laws andfacts of the case by computing interest at US LIBORfurther enhanced by more than 236% for risk profi leetc. which is completely unreasonable and against theaccepted industry norms.”
To know more in details find the attachent file
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