year. Arvind Mills Ltd. declared rights in the ratio of one convertible debenture for 10 shares held as on 18th Aug., 1992 (the record date ... assessee did not subscribe for the right offer of debentures but preferred to sell (renounce) these rights in favour of other group companies
next ground reads as follows :-
"Premium on Issue of debentures - Rs. 2,37,50,000. - CIT(A) has erred in not accepting the appellant ... being the premium payable on redemption of debentures is admissible deduction for the purpose of computation of total income of the assessment year
following income :
Rs.
(a) Government securities
9,07,500
(b) Debenture
1,40,000
(c) Commercial shares
65,924
(d) Other co-operatives ... income on Government securities Rs. 9,07,500 and income on debentures of GE Bond Rs. 1,40,000. It appears that the order under
form of Compulsorily Convertible
Debentures (CCDs) in M/s. Coffee Day Enterprises Ltd. Further, M/s. NSR PE,
6
ITA No.2931/Bang/2018 ... Bang/2019
TERMS AND CONDITIONS OF INVESTOR 3 CCDs
The compulsorily convertible debentures to be issued and allotted to the investor pursuant
to the Agreement
sugar; tea plantation or growing agricultural produce, etc. These companies, however, issued debentures and received deposits from employees and in some case also from public ... that the assessee-company received deposits by way of contribution to debentures under a scheme or arrangement and, therefore, it is a residuary non-banking
accrued to the appellant
as interest on Fully Convertible Debentures. Such
conclusions are opposed to the Terms of issue of
debentures.
10. The enhancement ... accrued to the
appellant as interest on Fully Convertible Debentures.
Such conclusions are opposed to the Terms of issue of
debentures.
6. The enhancement
crores made by the AO treating the surplus on redemption of debentures as revenue receipt holding that the debentures represent borrowed capital of the company ... cannot be treated as revenue receipt.
25. The assessee-company has issued debentures of the value of Rs. 40 crores during the accounting year ended
deduction of Rs. 22.85 lacs in respect of premium on redemption of debentures. The assessee had claimed the said amount as deduction under ... account of premium on redemption of non-convertible debentures being in the nature of additional interest. The AO disallowed the assessee's said claim
that the
assessee company has reduced Rs.225.00 crores relating to Debenture
Redemption Reserve (DRR) from the Net Profit, while computing Book profit ... assessee company did so treating the amount
appropriated to Debenture Redemption Reserve as an "ascertained liability".
The Ld Pr. CIT took the view
carries on, as its principal business, the acquisition of shares, stock, bonds, debentures, debenture stock, or securities issued by the Government or a local authority ... funds of the company in any manner including, amongst others, in debentures, stock, shares, etc. (Clause 66), and to undertake financial and commercial obligations, transactions
