Share application money cannot be treated as Loan unless Transaction is bogus

Voltas Limited Vs ACIT (ITAT Mumbai)

Share application money cannot be treated as Loan unless Transaction is bogus

We shall first deal with the claim of the revenue that the CIT(A) had erred in vacating the transfer pricing adjustment as regards charging of notional interest on the share application money that was given to its wholly owned subsidiary company viz. Saudi Ensas Company for Engineering Services WLL, UAE, for which allotment of shares was pending on 31.03.2012. In order to

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