https://www.taxtmi.com/caselaws?id=779852 ITAT set aside the lower authorities' orders and restored the matter to the AO/TPO for de novo re-examination of the transfer-pricing adjustment on interest paid on CCDs, holding that neither party's CUP comparables met Rule 10B(2)/(3) due to failures to adjust for convertibility (option value), subordination, security, industry risk and coupon structure. The Tribunal directed the AO/TPO to make appropriate adjustments and pass a reasoned order. Separately, additions for legal, professional, advertising and commission expenses were remanded to the AO to verify whether such costs should be capitalised as WIP or allowed as revenue expenditure. Appeal allowed for statistical purposes. en-us Mon, 15 Sep 2025 00:00:00 +0530 Tue, 14 Oct 2025 09:39:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779852 ITAT set aside the lower authorities' orders and restored the matter to the AO/TPO for de novo re-examination of the transfer-pricing adjustment on interest paid on CCDs, holding that neither party's CUP comparables met Rule 10B(2)/(3) due to failures to adjust for convertibility (option value), subordination, security, industry risk and coupon structure. The Tribunal directed the AO/TPO to make appropriate adjustments and pass a reasoned order. Separately, additions for legal, professional, advertising and commission expenses were remanded to the AO to verify whether such costs should be capitalised as WIP or allowed as revenue expenditure. Appeal allowed for statistical purposes. Case-Laws Income Tax Mon, 15 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779852