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

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