Preference Share Transactions Cannot Be Treated as Loans Without Evidence: ITAT Mumbai

Aegis Limited Vs DCIT (ITAT Mumbai) The Income Tax Appellate Tribunal (ITAT), Mumbai, adjudicated cross appeals filed by the assessee and the Revenue for Assessment Year 2010–11 arising from an assessment completed under section 143(3) read with section 144C(13), based on directions of the Dispute Resolution Panel (DRP). The assessee’s returned income was significantly enhanced following transfer pricing adjustments and other disallowances. The primary dispute related to transfer pricing adjustments of ₹88.02 crore concerning IT-enabled services (ITeS), preference share transactions, and...