Share application money cannot be treated as loan for mere delay in allotment

Advertisement Assessee argued that the clear transactions involving payment of share application money cannot be treated as international transactions of loans given by the assessee company to its AE merely because there was a delay in allotment of shares. It is observed that this contention of the ld. Counsel for the assessee is duly supported by the latest decision of Delhi Bench of this Tribunal in the case of Bharati Airtel Ltd. Vs. ACIT rendered vide its order dated 11-3-2014 passed in ITA No. 5816/Del/2012 wherein a similar issue has been decided by the Tribunal in favour of the asses...