During relevant year assessee gave certain money to its AE as share capital for allotment of shares. The TPO held that share transaction was sham and amount paid to AE was to be regarded as loan and made addition of notional interest. Tribunal held that the TPO could not recharacterize said transaction unless it was found to be a sham or bogus transaction. Accordingly, addition of notional interest made by TPO was deleted. Followed the order of earlier year.