Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
The NCLAT held that Compulsory Convertible Debentures (CCDs) issued by the Corporate Debtor constituted a 'financial debt' u/s 5(8) as the transaction involved time value of money. The debenture subscription agreement contemplated redemption and conversion was at the option of the investor. Considering the clauses, the CCDs reflected time value of money, making it a financial debt. The NCLAT dismissed the appeal, upholding the adjudicating authority's order allowing the respondent's application.
The NCLAT held that Compulsory Convertible Debentures (CCDs) issued by the Corporate Debtor constituted a 'financial debt' u/s 5(8) as the transaction involved time value of money. The debenture subscription agreement contemplated redemption and conversion was at the option of the investor. Considering the clauses, the CCDs reflected time value of money, making it a financial debt. The NCLAT dismissed the appeal, upholding the adjudicating authority's order allowing the respondent's application.
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