https://www.taxtmi.com/caselaws?id=310804 ITAT Mumbai allowed the assessee's appeal and quashed the PCIT's revision order u/s 263 regarding deduction of interest on Perpetual Non-Convertible Debentures (PNCDs). The tribunal held that the assessee had adequately explained the nature of PNCDs during assessment proceedings, citing relevant provisions of Companies Act and SEBI regulations. The Revenue's contention that perpetual debentures were akin to equity was rejected as the assessee had repaid the bonds with interest and notified stock exchanges as per SEBI requirements, proving these were genuine borrowings. Since the borrowings were used for business purposes, interest deduction u/s 36(1)(iii) was allowable. en-us Fri, 23 Dec 2022 00:00:00 +0530 Fri, 17 Nov 2023 20:53:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310804 ITAT Mumbai allowed the assessee's appeal and quashed the PCIT's revision order u/s 263 regarding deduction of interest on Perpetual Non-Convertible Debentures (PNCDs). The tribunal held that the assessee had adequately explained the nature of PNCDs during assessment proceedings, citing relevant provisions of Companies Act and SEBI regulations. The Revenue's contention that perpetual debentures were akin to equity was rejected as the assessee had repaid the bonds with interest and notified stock exchanges as per SEBI requirements, proving these were genuine borrowings. Since the borrowings were used for business purposes, interest deduction u/s 36(1)(iii) was allowable. Case-Laws Income Tax Fri, 23 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310804