https://www.taxtmi.com/caselaws?id=768169 ITAT held for the taxpayer that interest on rupee-denominated CCDs/FCCDs/NCDs and similar debentures must be benchmarked against domestic lending rates (PLR) rather than international rates (LIBOR). The tribunal found that where instruments are denominated in Indian currency they constitute rupee loans for transfer-pricing purposes, so applying LIBOR plus a margin was inappropriate. The TP adjustment was reversed and the appeal allowed, directing benchmark comparison with domestic prime lending rates. en-us Wed, 29 Jan 2025 00:00:00 +0530 Wed, 27 Aug 2025 14:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768169 ITAT held for the taxpayer that interest on rupee-denominated CCDs/FCCDs/NCDs and similar debentures must be benchmarked against domestic lending rates (PLR) rather than international rates (LIBOR). The tribunal found that where instruments are denominated in Indian currency they constitute rupee loans for transfer-pricing purposes, so applying LIBOR plus a margin was inappropriate. The TP adjustment was reversed and the appeal allowed, directing benchmark comparison with domestic prime lending rates. Case-Laws Income Tax Wed, 29 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768169