Transfer pricing adjustment on interest paid on compulsorily...

Transfer pricing adjustment on interest paid on compulsorily convertible debentures issued to a non-resident associated enterprise turned on the appropriate benchmark for arm's length interest where the CCDs were denominated in Indian currency. Applying the governing precedent, it was held that such INR-denominated CCD interest must be benchmarked using domestic Prime Lending Rate (PLR) rather than foreign currency benchmarks. Consequently, the adjustment/addition made by the tax authorities on account of ALP computation of interest on the CCDs was held unjustified and was deleted, and the appeal was allowed. - ITAT