M/S CENTURY INFRA POWER P. LTD.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, JAIPUR
In the result, appeal of the assessee is allowed
ITA 169/JPR/2019[2014-15]Status: DisposedITAT Jaipur02 Oct 2019AY 2014-15
For Appellant: Shri Manish Agarwal (CA)For Respondent: Sh. Bhanwar Singh (JCIT)
Section 143Section 143(2)Section 32(1)Section 92CSection 92C(3)
transfer pricing adjustments. Coming to the merit of the case, it is seen that the Ld. TPO made the adjustments on account of interest paid/ payable on unsecured loans from related parties. The TPO observed that the appellant has paid interest @ 15% to the related parties. The TPO adopted ALP of the interest @ 12.83% (PLR of SBI @ 9.83% + 300 basis
