International payment on FCCDs to be determined adopting average SBI PLR

JCIT (OSD) Vs ZF Wind Power Coimbatore Pvt. Ltd (ITAT Chennai) ITAT Chennai held that arm’s length price of interest paid on Fully Compulsory Convertible Debentures [FCCDs] issued in Indian denominated currency is to be determined by adopting average SBI Prime Lending Rate [PLR]. Facts-The case of the assessee was selected for scrutiny assessment and during the course of assessment proceedings, the case was referred to the Transfer Pricing Officer (TPO) to determine the arm’s length price of the International transactions undertaken by the assessee with its AEs. The TPO passed an order u/s...