https://www.taxtmi.com/caselaws?id=411459 The departmental appeal, despite being time-barred, was admitted for hearing after the condonation of the delay. The Tribunal upheld the CIT(A)'s reversal of re-characterizing debentures/CCDs as equity, directing re-determination of the ALP. Marg Limited was excluded as a comparable company due to lack of segmental details. The Tribunal deleted the addition under Section 43CA due to the retrospective application of the first proviso and increased safe harbor limit. The excess interest on debentures/CCDs for the assessment year 2013-14 was disallowed proportionately. The AO was directed to ascertain and allow the deduction for Education Cess and Secondary and Higher Secondary Cess. en-us Tue, 17 Aug 2021 00:00:00 +0530 Mon, 27 Jun 2022 16:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=411459 The departmental appeal, despite being time-barred, was admitted for hearing after the condonation of the delay. The Tribunal upheld the CIT(A)'s reversal of re-characterizing debentures/CCDs as equity, directing re-determination of the ALP. Marg Limited was excluded as a comparable company due to lack of segmental details. The Tribunal deleted the addition under Section 43CA due to the retrospective application of the first proviso and increased safe harbor limit. The excess interest on debentures/CCDs for the assessment year 2013-14 was disallowed proportionately. The AO was directed to ascertain and allow the deduction for Education Cess and Secondary and Higher Secondary Cess. Case-Laws Income Tax Tue, 17 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=411459