https://www.taxtmi.com/caselaws?id=790903 Transfer pricing treatment of interest on rupee-denominated non-convertible debentures turns on whether a 10% coupon paid to an associated enterprise is arm's length. The note records acceptance of the same rate in the prior year, treats the CBDT notification as relevant to the statutory ceiling for rupee-denominated instruments, and notes that the SBI PLR benchmark was used as supporting comparability while the MCLR objection was not accepted on the facts. It also corrects a computational error in the adjustment amount to match the figure actually adopted in 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 treatment of interest on rupee-denominated non-convertible debentures turns on whether a 10% coupon paid to an associated enterprise is arm's length. The note records acceptance of the same rate in the prior year, treats the CBDT notification as relevant to the statutory ceiling for rupee-denominated instruments, and notes that the SBI PLR benchmark was used as supporting comparability while the MCLR objection was not accepted on the facts. It also corrects a computational error in the adjustment amount to match the figure actually adopted in assessment proceedings. Case-Laws Income Tax Thu, 30 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790903