Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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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