https://www.taxtmi.com/caselaws?id=434274 Interest under Article 11 of the India-Cyprus tax treaty was treated as taxable only on actual payment or receipt, not on a merely notional or contingent basis. Applying the co-ordinate bench view in the assessee's own earlier year, the Tribunal held that the word "paid" in the treaty could not be expanded to include "payable". On that interpretation, no transfer pricing adjustment could be made on notional interest on fully convertible debentures where the amount had neither actually accrued in the relevant sense nor been received during the year. The adjustment based on a future contingent event was therefore unsustainable. en-us Wed, 30 Nov 2022 00:00:00 +0530 Mon, 20 Feb 2023 18:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434274 Interest under Article 11 of the India-Cyprus tax treaty was treated as taxable only on actual payment or receipt, not on a merely notional or contingent basis. Applying the co-ordinate bench view in the assessee's own earlier year, the Tribunal held that the word "paid" in the treaty could not be expanded to include "payable". On that interpretation, no transfer pricing adjustment could be made on notional interest on fully convertible debentures where the amount had neither actually accrued in the relevant sense nor been received during the year. The adjustment based on a future contingent event was therefore unsustainable. Case-Laws Income Tax Wed, 30 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434274