https://www.taxtmi.com/caselaws?id=461361 ITAT Hyderabad ruled in favor of the assessee regarding transfer pricing adjustment on interest paid to associated enterprises on compulsorily convertible debentures (CCDs). The TPO had treated CCDs as loans and applied LIBOR plus 200 basis points for interest determination. The Tribunal held that CCDs are hybrid instruments with equity characteristics, not loans, following SC precedent in Sahara Real Estate case and Delhi HC decision in Cotton Naturals. The Tribunal followed its own coordinate bench decision in assessee's case for AY 2013-14, allowing the appeal despite DRP's confirmation of TPO's order. en-us Fri, 18 Oct 2019 00:00:00 +0530 Tue, 01 Apr 2025 19:43:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461361 ITAT Hyderabad ruled in favor of the assessee regarding transfer pricing adjustment on interest paid to associated enterprises on compulsorily convertible debentures (CCDs). The TPO had treated CCDs as loans and applied LIBOR plus 200 basis points for interest determination. The Tribunal held that CCDs are hybrid instruments with equity characteristics, not loans, following SC precedent in Sahara Real Estate case and Delhi HC decision in Cotton Naturals. The Tribunal followed its own coordinate bench decision in assessee's case for AY 2013-14, allowing the appeal despite DRP's confirmation of TPO's order. Case-Laws Income Tax Fri, 18 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461361