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Transfer Pricing Adjustment on Non-Convertible Debentures: Verify Currency Consistency with Internal Comparables for Arm's Length Price.
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....TP Adjustment - ALP of interest on NDC’s [Non-convertible debentures] - NCD issued to associated enterprise is unsecured and loans taken from third parties are secured loans, hence, adjustment for this difference should be made as directed by the DRP in AY 2015- 16. Therefore, we remand the matter back to the TPO to verify if the currency of the internal comparables and NCD issued to associated enterprise is same - AT....