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Income Tax - Highlights / Catch Notes

Home Highlights January 2017 Year 2017 This

Treatment to issuance of CCDs as a loan - TPA - issuance of CCDs ...


Transfer Pricing Authority Mistakenly Treats Rupee-Denominated CCDs as Loans, Erroneously Using LIBOR as Benchmark Rate.

January 18, 2017

Case Laws     Income Tax     AT

Treatment to issuance of CCDs as a loan - TPA - issuance of CCDs was denominated in Indian Rupees and not foreign currency. Therefore, TPO has erred in considering LIBOR as benchmark rate which is in complete contradiction to the principles on the issue. - AT

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