Search Results For: Transfer Pricing investment in share capital of wholly owned subsidiary


Topsgrup Electronic Systems v ITO (ITAT Mumbai)

COURT:
CORAM: ,
SECTION(S): , , ,
GENRE:
CATCH WORDS:
COUNSEL:
DATE: February 19, 2016 (Date of pronouncement)
DATE: April 5, 2016 (Date of publication)
AY: 2009-10
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CITATION:
Transfer Pricing - alleged excess investment in share capital of wholly owned subsidiary cannot be termed as loan and notional interest charged thereon

The Tribunal deleted TP addition on account of a) alleged excess consideration paid on investment in share capital of wholly owned subsidiary re-characterized as loan b) and notional interest thereon on the ground that i. Chapter X of the Act is inapplicable to an international transaction on capital account which does not result in income chargeable to tax

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