https://www.taxtmi.com/caselaws?id=384365 The tribunal held that Compulsorily Convertible Debentures (CCDs) should be treated as debt until conversion, allowing interest on them as an expenditure. The issue of determining the appropriate interest rate for CCDs was remanded back for fresh consideration. The Thin Capitalisation Principle was deemed inapplicable in the absence of specific rules in India, rejecting the recharacterization of CCDs as equity. The Transfer Pricing Officer's rejection of comparability analysis was upheld, but the tribunal directed a re-examination of the arm's length price of interest on CCDs using the prescribed methods. en-us Thu, 25 Jul 2019 00:00:00 +0530 Sat, 10 Aug 2019 11:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=384365 The tribunal held that Compulsorily Convertible Debentures (CCDs) should be treated as debt until conversion, allowing interest on them as an expenditure. The issue of determining the appropriate interest rate for CCDs was remanded back for fresh consideration. The Thin Capitalisation Principle was deemed inapplicable in the absence of specific rules in India, rejecting the recharacterization of CCDs as equity. The Transfer Pricing Officer's rejection of comparability analysis was upheld, but the tribunal directed a re-examination of the arm's length price of interest on CCDs using the prescribed methods. Case-Laws Income Tax Thu, 25 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=384365