https://www.taxtmi.com/caselaws?id=305688 The Income Tax Appellate Tribunal (ITAT) upheld the Commissioner of Income Tax (Appeals) [CIT(A)]'s decision to use the average Prime Lending Rate (PLR) as the arm's length price for interest on fully convertible debentures issued to an associated enterprise. The ITAT dismissed the assessee's appeals, emphasizing that the risk factors were adequately addressed by the nature of the debentures and that market rates should be used for benchmarking, without double-counting risk elements. Both appeals were consequently dismissed on 22.04.2021. en-us Thu, 22 Apr 2021 00:00:00 +0530 Tue, 20 Dec 2022 10:04:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=305688 The Income Tax Appellate Tribunal (ITAT) upheld the Commissioner of Income Tax (Appeals) [CIT(A)]'s decision to use the average Prime Lending Rate (PLR) as the arm's length price for interest on fully convertible debentures issued to an associated enterprise. The ITAT dismissed the assessee's appeals, emphasizing that the risk factors were adequately addressed by the nature of the debentures and that market rates should be used for benchmarking, without double-counting risk elements. Both appeals were consequently dismissed on 22.04.2021. Case-Laws Income Tax Thu, 22 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=305688