ITAT Deletes Transfer Pricing Adjustment on 14% CCD Interest Paid to Foreign AE, Rejects Equity Recharacterisation of CCDs:
ITAT deletes the TP adjustment on Rs 94.33 crore CCD interest, holding that CCDs retain their debt character until conversion and that the 12.37% effective rate was within the comparable range.
ITAT Deletes TP Adjustment on Rs 94.33 Crore Interest
Saloni Kumari
Sep 10, 2026
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ITAT Deletes Transfer Pricing Adjustment on 14% CCD Interest Paid to Foreign AE, Rejects Equity Recharacterisation of CCDs
ITAT deletes the TP adjustment on Rs 94.33 crore CCD interest, holding that CCDs retain their debt character until conversion and that the 12.37% effective rate was within the comparable range.
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Saloni Kumari
Content Writer
Saloni is a Content Writer with 2+ years of experience at studycafe.in. She writes legal, taxation, and finance related content including GST, Income Tax etc. Skilled in translating complex judicial pronouncements and regulatory developments into clear, and reader-friendly articles. Experienced in covering judgements of ITAT, High Court, GSTAT, and news related to Income Tax, GST, and corporate law. She can be reached at [email protected].
Saloni is a Content Writer with 2+ years of experience at studycafe.in. She writes legal, taxation, and finance related content including GST, Income Tax etc. Skilled in translating complex judicial pronouncements and regulatory developments into clear, and reader-friendly articles. Experienced in covering judgements of ITAT, High Court, GSTAT, and news related to Income Tax, GST, and corporate law. She can be reached at [email protected].
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