ITAT Deletes CCD Interest Disallowance as Debentures Remain Debt Until Conversion

Goldman Sachs (India) Finance Pvt. Ltd. Vs Assessment Unit (ITAT Mumbai) The Income Tax Appellate Tribunal (ITAT), Mumbai, decided an appeal arising from the final assessment order for Assessment Year 2021-22 passed under Sections 143(3), 144C(13), and 144B of the Income Tax Act. The assessee challenged various additions and disallowances relating to occupancy expenses, Restricted Stock Unit (RSU) expenses, adjustments under Section 143(1), transfer pricing adjustment on interest paid on Compulsorily Convertible Debentures (CCDs), disallowance of interest on CCDs under Sections 36 and 37, TDS ...