ITAT Deletes TP Adjustment as CCDs Remain Debt Until Conversion

Stahl India Pvt. Ltd. Vs DCIT (ITAT Chennai) The assessee appealed against the final assessment order dated 19.07.2024 for Assessment Year 2020-21 passed under Sections 143(3), 144C(13), and 144B of the Income Tax Act. During the hearing, the assessee restricted its challenge to the transfer pricing adjustment relating to interest on Compulsorily Convertible Debentures (CCDs) and the disallowance of depreciation on goodwill arising from a slump sale. The assessee had issued CCDs worth ₹146 crore to its Associated Enterprise carrying interest at 11% per annum. The Transfer Pricing Officer (TP...