ECB Loan Waiver Not a Business Perquisite u/s 28(iv), No Non-Monetary Benefit or Perquisite Found.

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....Additions u/s 28(iv) - Business perquisite - ECB loan as received from the holding company by the assessee in convertible foreign exchange for the purpose of acquiring assets in the earlier years. The said loan has been waived and credited to the capital reserve - Therefore, there is no benefit or perquisite other than in the shape of money to invoke the provisions of section 28 (iv) - AT....