Transfer Pricing Adjustment on CCD Interest Deleted and Section 94B Interest Computation Restored
Transfer Pricing Adjustment on CCD Interest Deleted and Section 94B Interest Computation Restored Issue Whether the TPO can recharacterize Compulsorily Convertible Debentures (CCDs) as equity and reduce the arm’s length price (ALP) of interest to nil under Section 92C. Whether interest expense on CCDs can be disallowed under Section 36(1)(iii) or Section 37(1) without factual… Read More »