Coupon rate on CCDs treated as debt, depreciation allowed on goodwill from slump sale Pricing.

The ITAT determined that the 11% coupon rate on Compulsorily Convertible Debentures (CCDs) paid by the assessee company was within the arm's length range, based on benchmarking analysis. Consequently, the addition made by TPO/DRP, which treated CCDs as equity, was deemed incorrect, as CCDs are considered debt until conversion. Additionally, the ITAT allowed depreciation on goodwill from a slump sale under Section 32, aligning with jurisdictional High Court precedents that recognize goodwill as an intangible asset eligible for depreciation. .....

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