Summary
- The ITAT Chennai has partly allowed Siva Industries and Holdings Limited's appeal for AY 2015-16, rejecting significant transfer pricing adjustments related to overseas investments.
- The Tribunal deleted a ā¹6,22,05,255 adjustment on Optionally Fully Convertible Debentures, citing uncertainty in recovery and the real income principle.
- It also dismissed interest adjustments on loans to associated enterprises Winwind OY and Siva Skylink Global Ltd., emphasizing the impracticality of recovering these amounts.
- This ruling could reshape how notional interest is treated in transfer pricing cases, especially concerning uncertain recoveries.
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