Convertible debentures were held to be entirely equity in nature, since the contractual terms and accounting treatment showed no unilateral obligation to deliver cash and the stray note describing a compound financial instrument could not override substance. Accordingly, no transition amount arose under section 115JB(2C), and the deletion of the MAT adjustment was upheld. The Tribunal also held that the year of convergence governed the character of the instrument for later years, so the earlier coordinate bench ruling in the assessee's own case had to be followed on judicial discipline. For section 14A, the Assessing Officer failed to record the required dissatisfaction with the assessee's suo motu disallowance, making Rule 8D invocation unsustainable; the deletion was upheld.
Convertible debentures were held to be entirely equity in nature, since the contractual terms and accounting treatment showed no unilateral obligation to deliver cash and the stray note describing a compound financial instrument could not override substance. Accordingly, no transition amount arose under section 115JB(2C), and the deletion of the MAT adjustment was upheld. The Tribunal also held that the year of convergence governed the character of the instrument for later years, so the earlier coordinate bench ruling in the assessee's own case had to be followed on judicial discipline. For section 14A, the Assessing Officer failed to record the required dissatisfaction with the assessee's suo motu disallowance, making Rule 8D invocation unsustainable; the deletion was upheld.
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