https://www.taxtmi.com/caselaws?id=760173 ITAT Mumbai ruled in favor of appellant regarding transfer pricing adjustment on notional interest for share application money. TPO treated share application money as interest-free loan to AE due to alleged inordinate delay in share allotment. Tribunal held revenue failed to prove appellant's default caused the delay, accepting appellant's contention that delay resulted from non-receipt of SAIF Zone Authority approval despite proper application. Transfer pricing addition was deleted. Additionally, tribunal directed AO to re-compute income considering rectification order under Section 154, allowing all grounds raised by appellant. en-us Mon, 07 Oct 2024 00:00:00 +0530 Thu, 17 Oct 2024 09:24:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760173 ITAT Mumbai ruled in favor of appellant regarding transfer pricing adjustment on notional interest for share application money. TPO treated share application money as interest-free loan to AE due to alleged inordinate delay in share allotment. Tribunal held revenue failed to prove appellant's default caused the delay, accepting appellant's contention that delay resulted from non-receipt of SAIF Zone Authority approval despite proper application. Transfer pricing addition was deleted. Additionally, tribunal directed AO to re-compute income considering rectification order under Section 154, allowing all grounds raised by appellant. Case-Laws Income Tax Mon, 07 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760173