A recent decision of the Ahmedabad Income Tax Appellate Tribunal has been published concerning whether an adjustment may be made for notional interest on a convertible loan granted by an Indian parent to its foreign subsidiary. The case involved India-based Cadila Healthcare Ltd. (Cadila), a pharmaceuticals company, and the granting of convertible loans to its Irish subsidiary Zydus International Pvt. Ltd. (Zydus). Under the terms of the loans, Cadila had the option for repayment with interes…