Interest on FCCDs is to be computed by applying LIBOR plus 200 points

Fairfield Developments Limited Vs DCIT (ITAT Hyderabad)

ITAT Hyderabad held that FCCDs are debt hence interest paid/ payable on FCCDs in to be computed by applying LIBOR plus 200 basis points.

Facts- AO issued show cause asking as to why excess interest income of Rs. 13,98,41,656/ – be not taxed at 40% plus surcharge relying on article 11(7) of India – Cyprus DTAA. The assessee contended since the FCCD’s are in the nature of equity instruments and are den

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