3 Companies a, b, c make a private pool through Alternate investment fund category II , the fund made investment of 30 cr in NCD at cupon rate 8 percent and premium of 20 percent on redemption. The NCD were redeemed by fund in aug 24 and distributed the premium and interest to unit holders.
Whether sev 50AA is applicable and 115UB , in the hand of unit holder what should the correct head of income of premium capital gain/PGBP /OS
Section 115UB applies to pass through the income to unit holders in its original character, making the 8% coupon taxable under Income from Other Sources and the 20% redemption premium taxable under Capital Gains. Section 50AA does not apply to standard, fixed-rate NCDs as they are not Market Linked Debentures.
50AA also covers unlisted debenture which is transferred or redeemed on or after 23 july 2024
But I come through many instances where the ITAT and various AO have considered it income from other source , being a debt instruments ,,,
The assessee have also shown income from other source and set off his business loss
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