https://www.taxtmi.com/caselaws?id=314250 ITAT Bangalore held that the assessee's royalty payment to associated enterprises was at arm's length, rejecting TPO's 1% restriction based on prior tribunal decisions in the assessee's own case. Regarding CCDs, the tribunal ruled that until conversion, CCDs should be treated as debt for income tax purposes, allowing interest deduction despite RBI's equity classification for FDI policy. The interest rate benchmarking using average rupee cost compared to SBI prime lending rate was accepted. The TDS matter was remanded to AO for examination of the assessee's credit entitlement. en-us Thu, 15 Jun 2023 00:00:00 +0530 Tue, 28 May 2024 10:41:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314250 ITAT Bangalore held that the assessee's royalty payment to associated enterprises was at arm's length, rejecting TPO's 1% restriction based on prior tribunal decisions in the assessee's own case. Regarding CCDs, the tribunal ruled that until conversion, CCDs should be treated as debt for income tax purposes, allowing interest deduction despite RBI's equity classification for FDI policy. The interest rate benchmarking using average rupee cost compared to SBI prime lending rate was accepted. The TDS matter was remanded to AO for examination of the assessee's credit entitlement. Case-Laws Income Tax Thu, 15 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314250