Assessee-company issued Fully Compulsorily Convertible Debentures (FCCDs) to its foreign based Associated Enterprise (AE).  It made payment towards interest on FCCDs denominated in Indian Rupee to said AE.  TPO applied LIBOR based interest rates to benchmark aforesaid international transaction of payment of interest. Tribunal held that   interest should be market determined interest rate applicable to currency in which loan has to be repaid. Therefore lending rate was SBI Prime Lending Rate and, therefore, TPO was unjustified in using LIBOR based interest rate.