Tribunal held that the debentures issued by the assessee-company qualified as equity share capital and therefore, the debenture interest was allowable as deduction from the arm’s length price. Followed , Kolte Patil Developers Ltd. v. Dy.CIT (I. T. A. Nos. 1980 and 2111/Pun/2017 dated December 8, 2020). Matter remanded for verification .( AY.2013-14)
Amanora Future Towers P. Ltd. v. Dy. CIT (2021)85 ITR 16 (Trib) (SN)(Pune) (Trib)
S. 92C : Transfer pricing – Arm’s length price -Interest on debentures —Equity and not debt — Deduction allowable — Matter remanded [ S.92CA ]