https://www.taxtmi.com/caselaws?id=460731 The ITAT Mumbai held that no transfer pricing adjustment was warranted for interest on share application money paid by the assessee to its wholly owned subsidiary. The tribunal found that delayed allotment of shares by a wholly owned subsidiary does not prejudice the parent company's interests, and the assessee behaved commercially rationally by not charging interest during the delay period. Since the subsidiary was wholly owned, the timing of share allotment was benefit-neutral from a commercial perspective. The tribunal ruled that the Assessing Officer's adjustment treating share application money as a loan and imputing notional interest lacked legal and factual merit, directing deletion of the adjustment. Assessee's appeal was allowed. en-us Mon, 29 Feb 2016 00:00:00 +0530 Thu, 13 Feb 2025 19:08:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460731 The ITAT Mumbai held that no transfer pricing adjustment was warranted for interest on share application money paid by the assessee to its wholly owned subsidiary. The tribunal found that delayed allotment of shares by a wholly owned subsidiary does not prejudice the parent company's interests, and the assessee behaved commercially rationally by not charging interest during the delay period. Since the subsidiary was wholly owned, the timing of share allotment was benefit-neutral from a commercial perspective. The tribunal ruled that the Assessing Officer's adjustment treating share application money as a loan and imputing notional interest lacked legal and factual merit, directing deletion of the adjustment. Assessee's appeal was allowed. Case-Laws Income Tax Mon, 29 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460731