https://www.taxtmi.com/caselaws?id=314385 ITAT Bangalore allowed the assessee's appeal for statistical purposes in a transfer pricing case involving interest on Non-convertible Debentures issued to an Associated Enterprise. The TPO had made adjustments by applying coupon rates of 15% and 14.25% without considering the effective interest rate that factored in moratorium periods of 60 months, 58 months 11 days, and 24 months for different tranches. Following the Goodyear South Asia Tyres precedent, ITAT held that effective interest rates must be computed considering time value of money before benchmarking international transactions. The matter was remitted back to TPO for fresh analysis of the transfer pricing study. en-us Tue, 13 Sep 2022 00:00:00 +0530 Wed, 05 Jun 2024 20:08:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314385 ITAT Bangalore allowed the assessee's appeal for statistical purposes in a transfer pricing case involving interest on Non-convertible Debentures issued to an Associated Enterprise. The TPO had made adjustments by applying coupon rates of 15% and 14.25% without considering the effective interest rate that factored in moratorium periods of 60 months, 58 months 11 days, and 24 months for different tranches. Following the Goodyear South Asia Tyres precedent, ITAT held that effective interest rates must be computed considering time value of money before benchmarking international transactions. The matter was remitted back to TPO for fresh analysis of the transfer pricing study. Case-Laws Income Tax Tue, 13 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314385