Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Attachment of Pre Offence Mortgaged Property remains possible under PMLA; secured creditors may pursue statutory claim and seek auction with undertaki...
Transfer pricing adjustment on interest paid on compulsorily convertible debentures was held unsustainable where the TPO recharacterised the CCDs as equity and fixed the arm's length price of interest at nil. The Tribunal applied settled precedent that CCDs carrying stipulated interest cannot be treated as equity for this purpose, and that interest on such instruments cannot be disallowed merely because conversion into equity is contemplated later. It also relied on decisions allowing expenditure on issue of convertible debentures as revenue expenditure notwithstanding future conversion. The adjustment on account of interest expense on CCDs was therefore deleted.
Transfer pricing adjustment on interest paid on compulsorily convertible debentures was held unsustainable where the TPO recharacterised the CCDs as equity and fixed the arm's length price of interest at nil. The Tribunal applied settled precedent that CCDs carrying stipulated interest cannot be treated as equity for this purpose, and that interest on such instruments cannot be disallowed merely because conversion into equity is contemplated later. It also relied on decisions allowing expenditure on issue of convertible debentures as revenue expenditure notwithstanding future conversion. The adjustment on account of interest expense on CCDs was therefore deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
