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Compulsorily Convertible Debentures - debt or equity? Tax Tribunal rules

September 5, 2019[2019] 109 taxmann.com 34 (Article)
The Bangalore Bench of the Income-tax Appellate Tribunal (ITAT) in a recent decision in the case of CAE Flight Training (India) Pvt. Ltd.[ ITA No. 2060/Bang/2016] has ruled that compulsorily convertible debentures (CCDs) are to be regarded as debt, and not equity, for the purpose of the Income-tax Act, 1961 (the Act), and therefore, the interest on such CCDs would be allowable as a tax deductible expenditure under the Act.
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