ITAT Deletes ₹76.45 Crore TP Addition as CCDs Cannot Be Recharacterized as Equity

EBIXCASH World Money Limited Vs DCIT (ITAT Mumbai) The assessee, engaged in the business of money exchange and foreign exchange services and registered with the RBI, filed its return for AY 2022-23 declaring nil income. The assessee reported international transactions with its associated enterprise (AE), including payment of interest on Compulsorily Convertible Debentures (CCDs), and furnished Form 3CEB. The Assessing Officer referred the matter to the Transfer Pricing Officer (TPO) for determination of the arm’s length price (ALP) of interest paid on CCDs. The assessee had issued CCDs to it...