TaxTMI 
TaxTMI 
2019 (5) TMI 2031
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....ma Neb, Sr. DR ORDER PER: N.K. BILLAIYA, AM This appeal by the assessee is preferred against the order of the Commissioner of Income Tax [Appeals]-XI New Delhi, dated 02.01.2012 for Assessment Year 2006-07. 2. The only grievance of the assessee is that the CIT (A) erred in confirming the addition of Rs. 36,55,900/- as interest income under the head income from other sources on share applicatio....
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....dated 21/11/2003. The assessee also contended that no interest should be charged on share application money given to said M/s Sweet Home Estate Pvt. Ltd. Since, it is not given as loan but represents share application money. 6. The contention of the assessee did not find any favour with the A.O who was of the firm belief that no unrelated party would give an amount of Rs. 3.04 crores without char....
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.... orders of the authorities below. A perusal of the assessment orders show that the A.O made the addition as a transfer pricing adjustment being transactions entered into between associated enterprises. It seems that the A.O has re-characterized the transaction of share application money as loan. Though, this issue was not agitated before the CIT (A) as ultimately the additions were made on the ass....