Where assessee was director and shareholder of company which issued zero coupon debentures redeemable after 9 years to its directors, however company converted same prematurely into equity shares during relevant year, entire accumulated interest income on debenture was deemed to be received by assessee upon conversion into equity shares and was to be brought to tax in relevant assessment year. Revision order is justified. (AY. 2013-14)
Sanjjay Saumyha (Mrs.) v. PCIT (2025) 210 ITD 337 (Chennai) (Trib.)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-
Income from other sources-Interest-Zero coupon debentures redeemable after 9 years to its directors-Premature converted in to equity-Interest amount deemed to be received upon conversion of debentures in to equity shares in relevant assessment year-Revision order is justified. [S. 2(24)(iv) 47(x),47(x)(a), 49(2), 56v 145]
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