Amount given for purchasing share holding cannot be treated as Loan for Section 2(22)(e)

ITO Vs GRA Enterprises (ITAT Delhi) Assessing Officer while framing the assessment notice observed that the assessee had received total unsecured laon expenditure of Rs. 22,21,29,723/-, during the year out of which an amount of Rs. 950,000,00/- was received from M/s Telecare Network India (P), a closely held company having its office at Zen House, 261, Kohinoor Enclave, Western Marg, Saidullajab, New Delhi. The Assessing Officer was of the view that as per share holding pattern profit and loss account and balance sheet of M/s Telecare Network India (P), shows that the assessee company had 37.2...