https://www.taxtmi.com/caselaws?id=469571 Compulsorily convertible debentures retained debt character until conversion, so they could not be re-characterised as equity merely because of compulsory convertibility; on that basis, setting the arm's length price of interest at nil was unsustainable. Capitalised interest on CCDs forming part of work-in-progress did not cease to be relevant for transfer pricing, because it could still affect profits, income, losses, or assets when reversed or capitalised later. The arm's length determination on that interest was therefore remitted for fresh examination on the merits, with any consequential adjustment to follow in the year of reversal of work-in-progress. en-us Wed, 15 Oct 2025 00:00:00 +0530 Mon, 22 Jun 2026 10:23:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469571 Compulsorily convertible debentures retained debt character until conversion, so they could not be re-characterised as equity merely because of compulsory convertibility; on that basis, setting the arm's length price of interest at nil was unsustainable. Capitalised interest on CCDs forming part of work-in-progress did not cease to be relevant for transfer pricing, because it could still affect profits, income, losses, or assets when reversed or capitalised later. The arm's length determination on that interest was therefore remitted for fresh examination on the merits, with any consequential adjustment to follow in the year of reversal of work-in-progress. Case-Laws Income Tax Wed, 15 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469571