Transfer Pricing Dispute: Court Rejects Retroactive Adjustment of Convertible Debenture Repayment Premium Claim.

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....TP Adjustment - Disallowance of claim of proportionate premium paid arising on account of repayment of optionally convertible debentures - the commercial arrangement entered into by the Assessee subsequent to the filing of return of income for the relevant previous year, cannot be applied retroactively to make additional claim leading to reduction of the income returned by the Assessee. - AT....