Transfer Pricing Authority Mistakenly Treats Rupee-Denominated CCDs as Loans, Erroneously Using LIBOR as Benchmark Rate.

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....Treatment to issuance of CCDs as a loan - TPA - issuance of CCDs was denominated in Indian Rupees and not foreign currency. Therefore, TPO has erred in considering LIBOR as benchmark rate which is in complete contradiction to the principles on the issue. - AT....