ITAT Deletes Transfer Pricing Adjustment as CCDs Are Not Call Options

Indorama Ventures Oxides Ankleshwar Private Limited Vs Assessment Unit (ITAT Mumbai) The assessee appealed against the final assessment order passed under Sections 143(3), 144C(13), and 144B of the Income Tax Act for Assessment Year 2020-21. The appeal challenged transfer pricing adjustments relating to an alleged embedded call option in Compulsorily Convertible Debentures (CCDs), acquisition of a business undertaking, and disallowance of interest paid on CCDs. The assessee, engaged in the manufacture of surfactants, acquired the surfactants business of Huntsman International (India) Private L...