The ITAT held that the coupon rate of 11% paid by the assessee ...
Coupon rate on CCDs treated as debt, depreciation allowed on goodwill from slump sale Pricing.
January 9, 2025
Case Laws Income Tax AT
The ITAT held that the coupon rate of 11% paid by the assessee company on Compulsorily Convertible Debentures (CCDs) was within the arm's length range based on benchmarking analysis. Hence, the addition made by TPO/DRP treating CCDs as equity was incorrect since CCDs remain debt until converted. Regarding depreciation on goodwill from slump sale, the ITAT allowed depreciation u/s 32, following jurisdictional High Court precedents that goodwill constitutes an intangible asset eligible for depreciation.
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