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No addition for ALP adjustment on account of exchange difference for notional conversions of balances
Case Law Details
- Case Name
- Bennett Coleman &
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 30/08/2021
- Courts
- All ITAT, ITAT Mumbai
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Bennett Coleman & Co Ltd Vs DCIT (ITAT Mumbai)
Conclusion: An interest-free debt funding of an overseas company in the nature of a special purpose vehicle (SPV), with a corresponding obligation to use it for the purpose of acquisition of a target company abroad, could not be compared with a loan simpliciter, and be, subjected to an arm’s length price adjustment on account of notional interest on a loan by assessee company to its fully owned foreign subsidiary as balances reflected on account of exchange difference for notional conversions could not be treated as outstanding dues.
Held: T...
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