https://www.taxtmi.com/caselaws?id=250059 Gains from transfer of compulsorily convertible debentures held as capital assets were treated as capital gains, not interest, and treaty protection was not denied on an interest-characterisation basis. The Court held that call and put options, conversion mechanics, and exit terms did not convert a commercial investment into an interest-bearing loan. It also rejected piercing the corporate veil, finding that board participation, quorum rules, affirmative vote items, related-party controls, and audit arrangements showed operational separation and commercial purpose. On the whole transaction, the revenue had not proved a sham, colourable device, or disguised loan. en-us Wed, 30 Jul 2014 00:00:00 +0530 Fri, 01 Aug 2014 19:29:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=250059 Gains from transfer of compulsorily convertible debentures held as capital assets were treated as capital gains, not interest, and treaty protection was not denied on an interest-characterisation basis. The Court held that call and put options, conversion mechanics, and exit terms did not convert a commercial investment into an interest-bearing loan. It also rejected piercing the corporate veil, finding that board participation, quorum rules, affirmative vote items, related-party controls, and audit arrangements showed operational separation and commercial purpose. On the whole transaction, the revenue had not proved a sham, colourable device, or disguised loan. Case-Laws Income Tax Wed, 30 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=250059