https://www.taxtmi.com/caselaws?id=799032 Rectification under section 254(2) applies where a remand direction conflicts with findings already recorded. Compulsory convertible debentures, having been treated wholly as debt until conversion rather than artificially split into debt and equity components under Ind AS-32, required no fresh transfer-pricing benchmarking where the interest rate on the debt component had already been accepted as arm's length. The conflicting direction for de novo benchmarking was deleted. Consequently, the interest adjustment attributed to a purported equity component and the related disallowance were unsustainable and deleted. en-us Tue, 21 Jul 2026 00:00:00 +0530 Wed, 16 Sep 2026 08:38:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799032 Rectification under section 254(2) applies where a remand direction conflicts with findings already recorded. Compulsory convertible debentures, having been treated wholly as debt until conversion rather than artificially split into debt and equity components under Ind AS-32, required no fresh transfer-pricing benchmarking where the interest rate on the debt component had already been accepted as arm's length. The conflicting direction for de novo benchmarking was deleted. Consequently, the interest adjustment attributed to a purported equity component and the related disallowance were unsustainable and deleted. Case-Laws Income Tax Tue, 21 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799032