ITAT Confirms 11% CCD Coupon Rate as Arm's Length; Allows Depreciation on Goodwill from Slump Sale u/s 32.

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....The ITAT held that the coupon rate of 11% paid by the assessee company on Compulsorily Convertible Debentures (CCDs) was within the arm's length range based on benchmarking analysis. Hence, the addition made by TPO/DRP treating CCDs as equity was incorrect since CCDs remain debt until converted. Regarding depreciation on goodwill from slump sale, the ITAT allowed depreciation u/s 32, following jurisdictional High Court precedents that goodwill constitutes an intangible asset eligible for depreciation.....