https://www.taxtmi.com/caselaws?id=444828 ITAT Hyderabad upheld transfer pricing adjustment for interest on non-convertible debentures between assessee and DB International (Asia) Ltd, confirming their associated enterprise status under Section 92A(2) regardless of timing of control acquisition. The tribunal rejected assessee's comparables due to credit rating and tenor mismatches, applying safe harbor guidance to determine 12.275% as arm's length price against assessee's 13.13% rate. For debenture issue expenses, ALP was set at 1.5% versus assessee's 2.5% payment. Addition under Section 56(2)(viia) was deleted, directing use of balance sheet dated closest to transfer date for valuation. Section 14A disallowance was deleted as no exempt income was received. TDS credit issue was remanded to AO for verification. en-us Wed, 27 Sep 2023 00:00:00 +0530 Wed, 25 Oct 2023 10:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444828 ITAT Hyderabad upheld transfer pricing adjustment for interest on non-convertible debentures between assessee and DB International (Asia) Ltd, confirming their associated enterprise status under Section 92A(2) regardless of timing of control acquisition. The tribunal rejected assessee's comparables due to credit rating and tenor mismatches, applying safe harbor guidance to determine 12.275% as arm's length price against assessee's 13.13% rate. For debenture issue expenses, ALP was set at 1.5% versus assessee's 2.5% payment. Addition under Section 56(2)(viia) was deleted, directing use of balance sheet dated closest to transfer date for valuation. Section 14A disallowance was deleted as no exempt income was received. TDS credit issue was remanded to AO for verification. Case-Laws Income Tax Wed, 27 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444828