TPO's re-characterization of share subscription as loan overturned; no evidence of sham transaction, notional interest disallowed. https://www.taxtmi.com/highlights?id=45905 Disallowance of notional interest under TP - TPO had re-characterised the transaction of subscription of shares into advancing of unsecured loans - Nothing is brought on record by the Revenue to suggest that the transaction was sham - TPO could not have treated such transaction as a loan and charged interest thereon on notional basis en-us Tue, 16 Apr 2019 15:13:57 +0530 Tue, 16 Apr 2019 15:13:57 +0530 TaxTMI RSS Generator TPO's re-characterization of share subscription as loan overturned; no evidence of sham transaction, notional interest disallowed. https://www.taxtmi.com/highlights?id=45905 Disallowance of notional interest under TP - TPO had re-characterised the transaction of subscription of shares into advancing of unsecured loans - Nothing is brought on record by the Revenue to suggest that the transaction was sham - TPO could not have treated such transaction as a loan and charged interest thereon on notional basis Highlights Income Tax Tue, 16 Apr 2019 15:13:57 +0530 https://www.taxtmi.com/highlights?id=45905