Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Alternative statutory remedy under GST bars writ challenge where classification, notice variance, and hearing disputes require factual appellate revie...
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Compulsorily convertible debentures remain debt until conversion, notwithstanding mandatory conversion, absence of principal repayment, regulatory classification or accounting treatment. Their interest must therefore be benchmarked as debt for arm's-length pricing; treating pre-conversion CCDs as equity and fixing interest at nil is unsustainable. Debt-equity recharacterisation is contemplated under Chapter X-A only where an arrangement is declared impermissible and the prescribed procedure is followed. As that procedure was not invoked, the transfer-pricing adjustment based on recharacterisation of unsecured CCDs as equity was deleted.
Compulsorily convertible debentures remain debt until conversion, notwithstanding mandatory conversion, absence of principal repayment, regulatory classification or accounting treatment. Their interest must therefore be benchmarked as debt for arm's-length pricing; treating pre-conversion CCDs as equity and fixing interest at nil is unsustainable. Debt-equity recharacterisation is contemplated under Chapter X-A only where an arrangement is declared impermissible and the prescribed procedure is followed. As that procedure was not invoked, the transfer-pricing adjustment based on recharacterisation of unsecured CCDs as equity was deleted.
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