Shanti Prime Publication Pvt. Ltd.
Sec. 92B of Income Tax Act, 1961 —Transfer Pricing — DRP was right in holding that the said transaction is International Transactions as the AE was without any creditworthiness in spite of the assets sought to be bought as there were no factor to comfort the lenders to grant commercial loans at competitive rates as held by the TPO/DRP but as regards the rate is concerned by following the decision in case of Fresenius Kabi Oncology Ltd. (Supra) matter was remanded back to the file of the Assessing Officer/TPO with the direction that the same should be taken as 1% — Unitech Ltd. vs. Dy. CIT [2020] 180 Itd 653 (DEL)