https://www.taxtmi.com/caselaws?id=797369 Compulsorily convertible debentures remain debt instruments until conversion for transfer-pricing purposes. Chapter X requires benchmarking of the transaction actually undertaken, and a valid borrowing cannot be re-characterised as equity merely because conversion is compulsory or because of regulatory or accounting classifications. Interest therefore cannot be assigned a nil arm's length price on that basis; the CUP analysis and any Rule 10B comparability adjustments require examination on their merits. Bad-debt deduction is available where trade receivables are actually written off and the statutory conditions are met. Continuing dealings with debtors, or the absence of recovery action, does not by itself disprove a bona fide write-off. en-us Wed, 08 Jul 2026 00:00:00 +0530 Fri, 21 Aug 2026 08:28:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797369 Compulsorily convertible debentures remain debt instruments until conversion for transfer-pricing purposes. Chapter X requires benchmarking of the transaction actually undertaken, and a valid borrowing cannot be re-characterised as equity merely because conversion is compulsory or because of regulatory or accounting classifications. Interest therefore cannot be assigned a nil arm's length price on that basis; the CUP analysis and any Rule 10B comparability adjustments require examination on their merits. Bad-debt deduction is available where trade receivables are actually written off and the statutory conditions are met. Continuing dealings with debtors, or the absence of recovery action, does not by itself disprove a bona fide write-off. Case-Laws Income Tax Wed, 08 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797369