ITAT Deletes MAT Addition Because Convertible Debentures Were Not Compound Financial Instruments

ACIT Vs Reliance Industrial Investments and Holdings Limited (ITAT Mumbai) The appeals before the ITAT Mumbai arose from three separate orders passed by the National Faceless Appeal Centre (NFAC) for Assessment Years (AYs) 2018-19, 2019-20, and 2020-21. Since the issues were identical except for the figures involved, the Tribunal treated AY 2019-20 as the lead case. The principal issue concerned whether the assessee’s Zero Coupon Optionally Fully Convertible Debentures (ZOFCDs) and Fully Convertible Debentures (FCDs), issued to its holding company, should be treated as a “transition am...