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Transfer pricing adjustment on interest paid on non-convertible debentures was deleted because the assessee had already added the interest to total income and paid tax, and further disallowance would cause impermissible double taxation. The tribunal rejected revenue's suggestion that the disallowed interest was carried forward, noting returns and audit reports showed no such claim. The assessee was held entitled to the concessional tax rate under 115BAA despite delayed filing of Form 10-IC, the delay deemed a procedural lapse and covered by pandemic time extensions. Interest under sections 234B and 234C to be computed as directed.
Transfer pricing adjustment on interest paid on non-convertible debentures was deleted because the assessee had already added the interest to total income and paid tax, and further disallowance would cause impermissible double taxation. The tribunal rejected revenue's suggestion that the disallowed interest was carried forward, noting returns and audit reports showed no such claim. The assessee was held entitled to the concessional tax rate under 115BAA despite delayed filing of Form 10-IC, the delay deemed a procedural lapse and covered by pandemic time extensions. Interest under sections 234B and 234C to be computed as directed.
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