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The ITAT held that the coupon rate of 11% paid by the assessee company on Compulsorily Convertible Debentures (CCDs) was within the arm's length range based on benchmarking analysis. Hence, the addition made by TPO/DRP treating CCDs as equity was incorrect since CCDs remain debt until converted. Regarding depreciation on goodwill from slump sale, the ITAT allowed depreciation u/s 32, following jurisdictional High Court precedents that goodwill constitutes an intangible asset eligible for depreciation.
The ITAT held that the coupon rate of 11% paid by the assessee company on Compulsorily Convertible Debentures (CCDs) was within the arm's length range based on benchmarking analysis. Hence, the addition made by TPO/DRP treating CCDs as equity was incorrect since CCDs remain debt until converted. Regarding depreciation on goodwill from slump sale, the ITAT allowed depreciation u/s 32, following jurisdictional High Court precedents that goodwill constitutes an intangible asset eligible for depreciation.
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TaxTMI 
TaxTMI 
