LIBOR based interest rate cannot be applied to benchmark a financial transaction which is not denominated in foreign currency

Assotech Moonshine Urban Developers Pvt. Ltd. Vs DCIT (ITAT Delhi)  It is pertinent to note that during the year, the assessee company had issued 64,08,999 number of Fully Convertible Debentures (FCD) of Rs. 100/- each @ 17.75% per annum to SA Mallika Ventures Ltd., Cyprus i.e. Associated Enterprises) and the amount paid/payable towards interest to the said AE was Rs. 2,34,84,098/- during the year. The said amount of Rs. 2,34,84,098/- has been computed by the assessee company having regard to the arm’s length price as per the provisions of Section 92C of the Income Tax Act, 1961. The su...