X is an issuer of a share (which is not an equity share) and -X is obliged to redeem that share in whole or part; or the share is redeemable at the option of Y who is the holder or -Within a period of 3 years from the date of issue Therefore the share is a hybrid equity instrument X is an issuer of a share and -X is obliged to redeem that share in whole or part; or the share is redeemable at the option of Y who is the holder; or -Within a period of 3 years from the date of issue Therefore the share is a hybrid equity instrument Company Y is the issuer of a share and on the date of issue, the existence of the company -Is to be terminated within a period of 3 years or is likely to be terminated within a period of 3 years Therefore the share is a hybrid equity instrument Therefore any dividend or foreign dividend in respect of a hybrid equity instrument held by X shall be deemed to be income. Hybrid debt instrument X is an issuer of an instrument and -The instrument is at the option of X convertible into shares of X within a period of 3 years from the date of issue Therefore the item is a hybrid debt instrument X is an issuer of an instrument and -X is entitled to repay the instrument in whole or part by issue of shares of X within a period of 3 years from the date of issue Therefore the item is a hybrid debt instrument X is an issuer of an instrument and -X is entitled to repay the instrument in whole or part X within a period of 3 years from the date of issue and is entitle at the time of repayment to require the holder(Y) to acquire share of X Therefore the item is a hybrid debt instrument X is an issuer of an instrument and - The instrument is at the option of the holder(Y) convertible into shares of X within a period of 3 years from the date of issue and on the date of conversion the value of is likely to exceed the value of instrument by 20% Therefore the item is a hybrid debt instrument No deduction is allowed in respect of amount payable by issuer of hybrid debt instrument