https://www.taxtmi.com/caselaws?id=790903 Transfer pricing of interest on rupee-denominated non-convertible debentures issued to an associated enterprise is assessed by reference to the factual matrix and comparable domestic lending rates. A 10% interest rate was treated as arm's length, supported by the prior-year acceptance of the same rate against SBI PLR and by the statutory interest ceiling for rupee-denominated bonds; application of MCLR was not accepted on the recorded facts. The discussion also identifies a computational error caused by carrying forward earlier-year figures. The transfer pricing adjustment was required to be corrected to the amount actually proposed and adopted in the relevant assessment proceedings. en-us Thu, 30 Apr 2026 00:00:00 +0530 Sat, 02 May 2026 07:40:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790903 Transfer pricing of interest on rupee-denominated non-convertible debentures issued to an associated enterprise is assessed by reference to the factual matrix and comparable domestic lending rates. A 10% interest rate was treated as arm's length, supported by the prior-year acceptance of the same rate against SBI PLR and by the statutory interest ceiling for rupee-denominated bonds; application of MCLR was not accepted on the recorded facts. The discussion also identifies a computational error caused by carrying forward earlier-year figures. The transfer pricing adjustment was required to be corrected to the amount actually proposed and adopted in the relevant assessment proceedings. Case-Laws Income Tax Thu, 30 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790903