Dismissing the appeal of the revenue the Tribunal held that, recharacterization of the transaction of debt in to equity is not approved. Bench marking of interest payment to AES at 13. 75 % matter remanded. Additional ground on Education cess was allowed. (AY. 2013-14)
DCIT. v Kolte Patil Developers Ltd. (2021) 209 TTJ 364 / 198 DTR 1 (Pune)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Recharacterization of the transaction of debt in to equity is not approved-Bench marking of interest payment to AES at 13. 75 % matter remanded-Additional ground on Education cess was allowed. [S. 94B]