https://www.taxtmi.com/caselaws?id=780252 ITAT held that AE status under s92A(2) is determined if the condition is met at any time during the year; the assessee's challenge was dismissed. Interest on NCDs to be benchmarked at 12.275% (following tribunal practice); exclude redemption-premium portions already taxed earlier; give effect to remand benchmarking and s94B computation. Interest on foreign-currency CCDs benchmarked to SBI PLR - paid rate below PLR so AO/TPO's adjustment deleted. Voluntary disallowance negated need for TP benchmarking. No s14A disallowance as no exempt income. AO directed to recompute and allow set-off of unabsorbed depreciation (verify demerger transfer under s72A). Notional interest addition deleted. en-us Wed, 10 Sep 2025 00:00:00 +0530 Thu, 16 Oct 2025 12:58:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780252 ITAT held that AE status under s92A(2) is determined if the condition is met at any time during the year; the assessee's challenge was dismissed. Interest on NCDs to be benchmarked at 12.275% (following tribunal practice); exclude redemption-premium portions already taxed earlier; give effect to remand benchmarking and s94B computation. Interest on foreign-currency CCDs benchmarked to SBI PLR - paid rate below PLR so AO/TPO's adjustment deleted. Voluntary disallowance negated need for TP benchmarking. No s14A disallowance as no exempt income. AO directed to recompute and allow set-off of unabsorbed depreciation (verify demerger transfer under s72A). Notional interest addition deleted. Case-Laws Income Tax Wed, 10 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780252