IT(A) while deleting the addition has noted that as per the agreement, the interest was payable only if the conversion option was not exercised on the expiry of 5 year period. If at any time during the 5 year period conversion option was exercised and the loan was converted into equity, no interest accrued or become payable. He further noted that the funds were provided by the assessee as per RBI guidelines and in the immediately next year, the entire loan given to subsidiary was converted into equity shares of Zydus International (P) Ltd. He has further held that since the assessee has converted the loan into equity in the immediate next year, there was no question of taxing notional interest. He has further held that assessee had not granted interest-free loan but invested in Optionally convertible loan with a clause of interest in case conversion option was not exercised and further field the Assessee’s transaction with subsidiary was at arms length. Before us, the Revenue could not controvert the findings of CIT(A) by bringing any contrary material on record. In view of these facts, we find no reason to interfere with the order of CIT(A). 11. Respectfully following the findings of the Hon’ble High Court (supra) and the Co-ordinate Bench (supra), we direct the AO to delete the impugned additions, Ground No. 2 is accordingly allowed. 26. Thus, the distinguishing facts as canvassed by Shri Shrivastava do not culminate in to any proposition so as to convince us to take any divergence from earlier findings and the judicial discipline also guides us to follow the decision of the Co-ordinate Bench in the light of the ratio laid down by the Hon’ble Supreme Court and the Hon’ble jurisdictional High Court of Gujarat (supra) and considering the fact that the OFCD were on beneficial terms as per facts mentioned above. Consequently, we have no hesitation to follow earlier judgment in assessee’s own case as a result we delete the impugned additions. Ground No. 3 of assessee is allowed." 25.Considering the facts of the case in hand from all possible angles, we are of the considered opinion that the TPO/AO grossly erred in making notional addition being arm’s length interest on RPS. It would not be out of place to mention here that in asst. yr. 2012-13, preference shares have been redeemed by the AE and redemption has been accepted by the Revenue which is evident from p. 107 of the paper book. We conclude by holding that re-characterization of the transaction is erroneous and the resultant transfer pricing adjustment is uncalled for and deserves to be deleted. We accordingly direct the AO/TPO to delete the transfer pricing adjustment on this count from both the years under consideration. 26.In the result, the appeals of the assessee in ITA Nos. 1459/DEL/16 and 263/Del/20174 are allowed.