TPO's re-characterization of share subscription as loan overturned; no evidence of sham transaction, notional interest disallowed.

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....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....