https://www.taxtmi.com/caselaws?id=272736 Share application money remitted to a foreign subsidiary was treated as capital investment, not a loan, even though the balance remained pending allotment and was shown as unsecured loan in the subsidiary's accounts. Because shares were allotted substantially in the same year, with the balance allotted the next year, and there was no agreement for interest or other income from the remittance, the amount was not an international transaction under section 92B. The arm's length principle was therefore inapplicable, and no transfer pricing adjustment could be made on re-characterisation of the payment as debt. en-us Fri, 06 May 2016 00:00:00 +0530 Wed, 16 May 2018 06:42:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=272736 Share application money remitted to a foreign subsidiary was treated as capital investment, not a loan, even though the balance remained pending allotment and was shown as unsecured loan in the subsidiary's accounts. Because shares were allotted substantially in the same year, with the balance allotted the next year, and there was no agreement for interest or other income from the remittance, the amount was not an international transaction under section 92B. The arm's length principle was therefore inapplicable, and no transfer pricing adjustment could be made on re-characterisation of the payment as debt. Case-Laws Income Tax Fri, 06 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=272736