https://www.taxtmi.com/caselaws?id=796080 Interest on INR-denominated compulsorily convertible debentures issued to an associated enterprise must be benchmarked by reference to the currency in which the borrowing is denominated and repayable. LIBOR applies to foreign-currency borrowings and does not apply merely because the debenture holder is a foreign associated enterprise. Accordingly, INR-denominated CCDs should be compared with domestic INR-denominated debt instruments using the domestic prime lending rate. On this basis, benchmarking at domestic PLR rather than LIBOR plus a spread resulted in deletion of the transfer-pricing adjustment. en-us Tue, 30 Jun 2026 00:00:00 +0530 Fri, 31 Jul 2026 08:27:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796080 Interest on INR-denominated compulsorily convertible debentures issued to an associated enterprise must be benchmarked by reference to the currency in which the borrowing is denominated and repayable. LIBOR applies to foreign-currency borrowings and does not apply merely because the debenture holder is a foreign associated enterprise. Accordingly, INR-denominated CCDs should be compared with domestic INR-denominated debt instruments using the domestic prime lending rate. On this basis, benchmarking at domestic PLR rather than LIBOR plus a spread resulted in deletion of the transfer-pricing adjustment. Case-Laws Income Tax Tue, 30 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796080