COURT: | ITAT Mumbai |
CORAM: | Amit Shukla (JM), Jason P. Boaz (AM) |
SECTION(S): | 92, 92B, 92C, 92F |
GENRE: | Transfer Pricing |
CATCH WORDS: | Transfer Pricing investment in share capital of wholly owned subsidiary |
COUNSEL: | Sunil M. Lala |
DATE: | February 19, 2016 (Date of pronouncement) |
DATE: | April 5, 2016 (Date of publication) |
AY: | 2009-10 |
FILE: | Click here to view full post with file download link |
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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