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2020 (12) TMI 779 - AT - Income TaxTreatment of optionally and Compulsory Convertible Debentures issued by the assessee company as Equity Share Capital - HELD THAT:- The parties herein have agreed that the issue stands covered in favour of the assessee and after analyzing this issue and perusing the findings of the Pune Bench of the Tribunal. [2020 (12) TMI 747 - ITAT PUNE] we allow these grounds of appeal of the assessee. Thus, grounds pertaining to treatment of optionally and Compulsory Convertible Debentures issued by the assessee company as Equity Share Capital are allowed. Determination of ALP of the assessee company - HELD THAT:- As after analyzing the relevant documents on record, going through the orders of the sub-ordinate Authorities that the ALP of the assessee has to be freshly determined and in view thereof, we set aside the order of the Ld. CIT(Appeals) on this matter and restore the issue to the file of TPO/AO for fresh determination of ALP of the assessee after complying with the principles of natural justice. Thus, the ground of appeal raised by the assessee is allowed for statistical purposes.
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