No addition for TP Adjustment towards interest on debentures invested in AE

Gurgaon Investment Ltd. Vs DDIT (ITAT Mumbai) The issue under consideration is whether addition made on account of Transfer Pricing Adjustment towards interest on debentures invested in the Associated Enterprise (AE) Vital Construction Pvt. Ltd. (VCPL) is justified or not? Assessee, a non-resident company incorporated in Mauritius. Through one of its AEs based in Mauritius invested in CCDs of an Indian company, i.e., VCPL, wherein, assessee also had shareholding of 26%. As per terms and conditions of debenture, assessee was supposed to receive interest @ 12% per annum. However, considering the...