No addition for ALP adjustment on account of exchange difference for notional conversions of balances

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...