interest @ 15%,
interest should be allowed @ 12.62% being ALP of interest. The revenue is
in appeal against this finding of CIT (A) that CCDs ... held that as against the claim of interest @ 15%,
interest should be allowed @ 13.25% being ALP of interest by adopting
lowest PLR. The revenue
payment of interest
on Compulsory Convertible Debentures (CCDs), premium
expenditure on repayment of CCDs and interest on Rupee
Denominated Bonds (RDBs), by recharacterizing the same ... allowed.
10. Payment of interest on CCDs, premium expenditure on repayment of
CCDs and interest on RDBs (Ground Nos.4.7 to 4.14) (TP adjustment
management
services availed
Interest on 86,90,683 88,12,925
receivables
Interest on CCDs ... Thus
the total interest payable worked out to 2.63% as arm's length
interest.
7.5 The total amount of interest paid/payable
interest income and brought to tax the interest
income earned at the rates in force (approximately 42%).
The AO held that the investment in CCDs ... 2017
Following the direction of the DRP, the AO assessed the interest on
CCDs at normal rates i.e. without benefit of DTAA
assessment had examined the agreement
and other details relating to CCDs and interest thereon;
2.1.3. assessment made by the then TPO was neither erroneous ... CCDs. As per agreement dated 03.10.2013,
CCDs were issued for a period of 120 months (10 years) and the
interest rate payable
assessment had examined the agreement
and other details relating to CCDs and interest thereon;
2.1.3. assessment made by the then TPO was neither erroneous ... CCDs. As per agreement dated 03.10.2013,
CCDs were issued for a period of 120 months (10 years) and the
interest rate payable
CCDs' by applying LIBOR rates applicable to USD,
without appreciating the fact that CCDs issued are INR
denominated and the interest thereon is also ... classify CCDs as equity
for the limited purpose of regulating foreign
investments, given the hybrid nature of CCDs. Unlike
a traditional loan/debenture, CCDs must
royalty,
payment towards technical and support services and payment
of interest on CCDs. The transaction of payment of royalty
and towards technical and support services ... paid
interest of Rs.166,32,46,020 to Praxair International Finance
(PIxF Ireland) at interest rate of 9% and 12% on CCDs which
have
account of interest paid on NCDs and
Rs.86,88,495/- on account of interest paid on CCDs and non‑TP
addition ... addition made on account of
interest paid on NCDs and (b) addition made on account of interest
paid on CCDs. As far as the issue
account of interest paid on NCDs and
Rs.86,88,495/- on account of interest paid on CCDs and non‑TP
addition ... addition made on account of
interest paid on NCDs and (b) addition made on account of interest
paid on CCDs. As far as the issue
