https://www.taxtmi.com/caselaws?id=306940 The Tribunal allowed the appeal partly, deleting the transfer pricing adjustment on interest payment made on Compulsorily Convertible Debentures (CCDs) to a non-resident AE. The Tribunal held that CCDs should be treated as debt until conversion, allowing interest expenditure as deductible. It rejected the recharacterization of CCDs as equity by the lower authorities and emphasized compliance with thin capitalization rules under section 94B of the IT Act. While the transfer pricing adjustment was deleted, the disallowance under section 94B was upheld, resulting in a partial success for the appellant in the case. en-us Thu, 10 Nov 2022 00:00:00 +0530 Tue, 07 Mar 2023 00:20:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306940 The Tribunal allowed the appeal partly, deleting the transfer pricing adjustment on interest payment made on Compulsorily Convertible Debentures (CCDs) to a non-resident AE. The Tribunal held that CCDs should be treated as debt until conversion, allowing interest expenditure as deductible. It rejected the recharacterization of CCDs as equity by the lower authorities and emphasized compliance with thin capitalization rules under section 94B of the IT Act. While the transfer pricing adjustment was deleted, the disallowance under section 94B was upheld, resulting in a partial success for the appellant in the case. Case-Laws Income Tax Thu, 10 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306940