ITAT Mumbai held that Compulsorily Convertible Debentures cannot be equated with call options and that no option premium arose from their issuance. The transfer pricing adjustment was deleted as no taxable income was generated.
ITAT Bangalore held that RBI’s classification of compulsorily convertible debentures as equity for FDI purposes cannot determine their treatment under the Income Tax Act. The Tribunal ruled that interest on CCDs before conversion remains allowable.
ITAT Delhi held that no disallowance under Rule 8D(2)(ii) could be made where investments yielding exempt income were financed from the assessee’s own funds rather than borrowed funds.
ITAT Mumbai held that Compulsorily Convertible Debentures retain their character as debt until conversion into equity. It deleted the disallowance of interest under Sections 36 and 37 while remanding the transfer pricing benchmarking issue.
ITAT Chennai held that Compulsorily Convertible Debentures retain the character of debt until conversion into equity. It ruled that interest on CCDs is deductible and that the TPO could not recharacterise them as equity.
The Supreme Court held that an assessee who participates in assessment proceedings without objecting to jurisdiction within the period prescribed under Section 124(3)(a) cannot subsequently challenge the Assessing Officer’s jurisdiction.
The Allahabad High Court held that information regarding cash deposits constituted relevant material for issuing a notice under Section 148. It dismissed the writ petition while permitting the assessee to pursue the statutory appellate remedy.
The Allahabad High Court refused to recall its earlier judgment after holding that it had already delivered a detailed decision on merits and that no valid ground for recall was established.
ITAT Jaipur held that assessments initiated under Section 153C were time-barred under every possible computation of limitation. The assessment orders were declared void ab initio and quashed.
The Calcutta High Court granted the taxpayer an opportunity to reply after finding that the show cause notice was not received. The GST authority was directed to pass a fresh reasoned order after hearing the petitioner.
