ITAT Deletes Upward Adjustment on Payments of Interest On Fully Convertible Debentures in International Transaction

Altico Capital India Pvt. Ltd Vs ACIT (ITAT Mumbai)

Conclusion: The ITAT deleted the adjustment in respect of international transaction of Payment of Interest on ‘Fully Convertible Debentures’ by upholding the contentions that LIBOR was not applicable as there was no lending/borrowing in foreign currency and assessee had issued rupee dominated debentures. Also in earlier year, TPO has taken Indian rates for charging interest on FCDs and not LIBOR rate, and therefore the same transaction following/

Please become a Premium member. If you are already a Premium member, login here to access the full content.