TP Adjustment Deleted as INR-Denominated CCD Interest Must Follow PLR

Cinepolis India Private Limited Vs ACIT (ITAT Delhi) ITAT Delhi Deletes ₹9.35 Cr TP Adjustment on Interest on Rupee-Denominated CCDs; PLR to Prevail Over LIBOR Delhi Bench ‘H’ of the ITAT, in , deleted the transfer-pricing adjustment of ₹9.35 crore made on account of interest paid on compulsorily convertible debentures (CCDs) issued to a non-resident AE. The Tribunal held that where CCDs are denominated in Indian currency, the arm’s length interest must be benchmarked with reference to domestic Prime Lending Rate (PLR) and not LIBOR-based rates. Following the Special Bench decision i...