Preference Share Investment Cannot Be Treated as Loan Without Evidence: ITAT Mumbai

Aegis Limited Vs DCIT (ITAT Mumbai) The Income Tax Appellate Tribunal (ITAT), Mumbai, adjudicated the appeal for Assessment Year 2014–15 against the final assessment order passed under section 143(3) read with section 144C(13) pursuant to directions of the Dispute Resolution Panel (DRP). The principal issues related to transfer pricing adjustments arising from re-characterisation of preference share investments and disallowance of interest expenditure under section 36(1)(iii). The Transfer Pricing Officer (TPO) treated the closing balance of preference shares held by the assessee in its asso...