https://www.taxtmi.com/caselaws?id=289900 The ITAT ruled in favor of the assessee, rejecting the recharacterization of Fully Compulsory Convertible Debentures (FCCDs) as foreign loans for transfer pricing purposes. The Tribunal determined that FCCDs, issued in Indian Rupees, should not be benchmarked using LIBOR but rather SBI PLR and NSDL data. Consequently, the excessive transfer pricing addition was deleted. The Tribunal did not extensively address the levying of interest under sections 234B and 234D, as the focus remained on the transfer pricing adjustments. The appeal was allowed, affirming the assessee's position on the arm's length price determination for FCCD interest payments. en-us Thu, 25 Jan 2018 00:00:00 +0530 Thu, 14 Nov 2024 11:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289900 The ITAT ruled in favor of the assessee, rejecting the recharacterization of Fully Compulsory Convertible Debentures (FCCDs) as foreign loans for transfer pricing purposes. The Tribunal determined that FCCDs, issued in Indian Rupees, should not be benchmarked using LIBOR but rather SBI PLR and NSDL data. Consequently, the excessive transfer pricing addition was deleted. The Tribunal did not extensively address the levying of interest under sections 234B and 234D, as the focus remained on the transfer pricing adjustments. The appeal was allowed, affirming the assessee's position on the arm's length price determination for FCCD interest payments. Case-Laws Income Tax Thu, 25 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289900