Unpaid price cannot be said to be a loan advanced

Amount of the unpaid price cannot be said to be a loan advanced by the non-resident company to the assessee-company nor can be the non-resident company be said to be a lender to the assesse-company so far as that amount was concerned. Since the non-resident company cannot be said to have lent the amount of the unpaid purchase price to the assessee-company either in cash or in kind, there is no question of the interest payable by the assessee-company to the non-resident company being deemed to be “income” accruing or arising from any money lent at interest and brought into India in ...