https://www.taxtmi.com/caselaws?id=461376 ITAT Hyderabad held that fully convertible debentures (FCCDs) issued by assessee to associated enterprise constitute debt instruments until conversion to equity, rejecting assessee's characterization arguments. The tribunal upheld transfer pricing adjustment where assessee benchmarked interest at 17.75% using SBI prime lending rate plus 3%, while authorities applied LIBOR plus 200 basis points per RBI guidelines. Court ruled no recharacterization occurred since FCCDs inherently debt-natured pre-conversion, and authorities correctly applied arm's length pricing principles. Decision favored revenue authorities against assessee. en-us Wed, 21 Sep 2022 00:00:00 +0530 Tue, 01 Apr 2025 11:10:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461376 ITAT Hyderabad held that fully convertible debentures (FCCDs) issued by assessee to associated enterprise constitute debt instruments until conversion to equity, rejecting assessee's characterization arguments. The tribunal upheld transfer pricing adjustment where assessee benchmarked interest at 17.75% using SBI prime lending rate plus 3%, while authorities applied LIBOR plus 200 basis points per RBI guidelines. Court ruled no recharacterization occurred since FCCDs inherently debt-natured pre-conversion, and authorities correctly applied arm's length pricing principles. Decision favored revenue authorities against assessee. Case-Laws Income Tax Wed, 21 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461376