https://www.taxtmi.com/caselaws?id=801788 Compulsorily convertible debentures carrying a fixed coupon, no pre-conversion voting rights and a debtor-creditor relationship retain debt character until conversion. Compulsory conversion alone does not support equity recharacterisation, a nil arm's-length price for interest, or an interest disallowance based on equity treatment; transfer-pricing analysis must follow the prescribed framework. Business-support-services adjustments require fresh consideration where additional evidence on service rendition, cost allocation and benchmarking was not assessed. A deduction claim supported by revised computation and certification requires factual examination of statutory conditions, prescribed-form compliance and procedural requirements. en-us Tue, 06 Oct 2026 00:00:00 +0530 Tue, 27 Oct 2026 08:33:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801788 Compulsorily convertible debentures carrying a fixed coupon, no pre-conversion voting rights and a debtor-creditor relationship retain debt character until conversion. Compulsory conversion alone does not support equity recharacterisation, a nil arm's-length price for interest, or an interest disallowance based on equity treatment; transfer-pricing analysis must follow the prescribed framework. Business-support-services adjustments require fresh consideration where additional evidence on service rendition, cost allocation and benchmarking was not assessed. A deduction claim supported by revised computation and certification requires factual examination of statutory conditions, prescribed-form compliance and procedural requirements. Case-Laws Income Tax Tue, 06 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801788