https://www.taxtmi.com/caselaws?id=5569 A loan arrangement in favour of the assessee's children was found to be a paper device, not a genuine borrowing, because funds were round-tripped through the books on the same day without real loan substance. On that factual characterisation, the interest arising from the arrangement was assessable in the assessee's hands under anti-avoidance principles governing direct and indirect transfers. The Supreme Court also noted that, in the section 256 reference, the High Court did not exceed its jurisdiction by sustaining that legal characterisation on the facts found. en-us Thu, 06 Mar 1997 00:00:00 +0530 Fri, 15 May 2015 17:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5569 A loan arrangement in favour of the assessee's children was found to be a paper device, not a genuine borrowing, because funds were round-tripped through the books on the same day without real loan substance. On that factual characterisation, the interest arising from the arrangement was assessable in the assessee's hands under anti-avoidance principles governing direct and indirect transfers. The Supreme Court also noted that, in the section 256 reference, the High Court did not exceed its jurisdiction by sustaining that legal characterisation on the facts found. Case-Laws Income Tax Thu, 06 Mar 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5569