Dismissing the appeal of the revenue the Court held that the bonds were issued under the 1993 Scheme and the conversion price was determined on the basis of price of shares at the Bombay Stock Exchange or the National Stock Exchange on the date of conversion of the foreign currency convertible bonds into shares. The computation of capital gains by the assessee was right. (AY.2008-09)
DIT (IT) v. Intel Capital (Cayman) Corporation (2020) 429 ITR 45 / 195 DTR 382 / 317 CTR 702 / (2021) 276 Taxman 118 (Karn.)(HC)
S. 115AC : Capital gains-Bonds-Global Depository-Foreign currency-Cost of acquisition-Computation of capital gains-Conversion of Foreign currency convertible bonds into equity shares-Order of Tribunal is affirmed.