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Tax Publishers
Treatment of Zero coupon Optionally Optionally
fullyconvertible debenture (ZOFCD) under Ind-AS transition under MAT Section
115JB(2C) 1/5th spread over
Fact:
PCIT
reopened the assessee's case under section 263 alleging that the Zero coupon
optionally convertible debentures triggered the transitional provision under
section 115JB(2C) and since the AO did not consider the impact of the
same, the order was prejudicial to the interests of revenue. On appeal
Held on facts that the ZOFCD did not have any financial
liability component thus invocation of section 115JB(2C) was unwarranted.
Ed. Note: The decision elaborately discusses many points on IFRS
valuation of financial instruments.
Case: Reliance Industrial Investment & Holdings Ltd. v. DCIT 2023
TaxPub(DT) 2139 (Mum-Trib)
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