272 ITR

Section 92

AAR : Whether the granting of loan amounting to Rs. 360 millions by the applicant, being a nonresident corporate assessee, in favour of Datex-Ohmeda (India) (P) Ltd. (hereinafter referred to as “Datex”), which is its wholly- owned subsidiary company incorporated in India, without charging any interest, and accordingly without adhering to the principles of arm’s length price, actually results in the Government exchequer or the tax revenue of the country being benefited ?

Authority For Advance Rulings Instrumentarium Corporation, In Re Sections 92, 92(3), 245N(a), 245R(2), Proviso Syed Shah Mohammed Quadri, J., Chairman

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