Compulsorily Convertible Debentures: Interest Allowable as Debt Until Conversion u/s 36(1)(iii) of Income Tax Act.

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....TP adjustment - Recharacterising the compulsorily convertible debentures (`CCDs') as equity shares - till the date of conversion, for allowability of interest u/s 36 (1) (iii) of Income tax Act also, such CCDs are to be considered as Debt only and interest thereon has to be allowed and it cannot be disallowed by saying that CCDs are equity and not debt. - AT....