https://www.taxtmi.com/caselaws?id=188207 An enhanced open-offer payment received for tendering shares was held to form part of the share sale consideration, not separate interest. The additional amount arose from a SEBI-approved revised offer price and was linked to delay in completing the acquisition process, but it was not paid on any debt, loan, or credit facility. As there was no debtor-creditor relationship, the receipt could not be split into principal consideration and penal interest. It therefore did not fall within the definition of interest under the Income-tax Act or the relevant tax treaty and was treated as part of the transfer consideration. en-us Fri, 29 Jan 2016 00:00:00 +0530 Tue, 22 Nov 2016 11:46:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=188207 An enhanced open-offer payment received for tendering shares was held to form part of the share sale consideration, not separate interest. The additional amount arose from a SEBI-approved revised offer price and was linked to delay in completing the acquisition process, but it was not paid on any debt, loan, or credit facility. As there was no debtor-creditor relationship, the receipt could not be split into principal consideration and penal interest. It therefore did not fall within the definition of interest under the Income-tax Act or the relevant tax treaty and was treated as part of the transfer consideration. Case-Laws Income Tax Fri, 29 Jan 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=188207