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ITAT Chennai: Uncertain OFCD Recovery Prevents Notional Interest Addition in TP Case

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Summary

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  • 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 ₹6,22,05,255 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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