PLR Rates Are Not Applicable To Loans To Be Re-Paid In Foreign Currency Vis-À-Vis Interest On Delayed Realization: Mumbai ITAT

The Mumbai ITAT clarified that interest rates on FCNR accounts maintained in foreign currency are different and dependent upon the currency in question. They are not dependent upon the PLR rate, which is applicable to loans in Indian rupee.The ITAT therefore deleted the ALP adjustments qua Letter of Comfort and interest on delayed realization of sale proceeds from the AEs.Referring to decision...