https://www.taxtmi.com/caselaws?id=792985 Compulsorily convertible debentures were treated as debt-like instruments until conversion, so contractual interest could not be disallowed by recharacterising them as equity for transfer pricing purposes. The Tribunal held that a nil arm's length price for the interest component, based only on the view that the instrument resembled share capital and carried no repayment obligation, was not justified without a valid benchmarking exercise. On that reasoning, the transfer pricing adjustment was found unsustainable and the addition was deleted in full in favour of the assessee. en-us Thu, 04 Jun 2026 00:00:00 +0530 Sat, 06 Jun 2026 08:42:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792985 Compulsorily convertible debentures were treated as debt-like instruments until conversion, so contractual interest could not be disallowed by recharacterising them as equity for transfer pricing purposes. The Tribunal held that a nil arm's length price for the interest component, based only on the view that the instrument resembled share capital and carried no repayment obligation, was not justified without a valid benchmarking exercise. On that reasoning, the transfer pricing adjustment was found unsustainable and the addition was deleted in full in favour of the assessee. Case-Laws Income Tax Thu, 04 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792985