Held, that the compulsorily convertible debentures could not be categorised as a loan and the transfer pricing study done by the assessee to arrive at the interest rate of nine per cent. and 12 per cent. with regard to payment of interest on compulsorily convertible debentures was proper. (AY. 2013-14)
Praxair India P. Ltd. v. Dy. CIT (2023)101 ITR 640 (Bang) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Determination-Payment of interest on compulsorily convertible debentures-Cannot be regarded as loan-Interest cannot be computed on libor-Interest rate of 9 and 12 percent justified.[S.92]