Aurionpro Solutions Ltd. v. Addl. CIT
What is Aurionpro Solutions Ltd. v. Addl. CIT authority for?
For benchmarking inter-company loans, the arm's length price (ALP) should not be below the cost of the assessee's borrowings, and the income earned should be what the assessee would have earned by lending to third parties. The Transfer Pricing Officer (TPO) can consider various methods, including the bank prime lending rate (PLR), corporate bond rates, or domestic borrowing costs, when applying the External CUP method.
judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.
Also referred to as
Aurionpro Solutions Ltd. v. Addl. CIT · 2013 · ITAT · Section 92C · Section 92F · arm's length price · ALP · inter-company loans · cost of borrowings · External CUP method · benchmark rate
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Issues it is cited on
Judgments citing Aurionpro Solutions Ltd. v. Addl. CIT
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