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Mere buy-back of shares at issue price couldn't be held as interest-free loans in garb of investment in subsidiary

February 10, 2017[2017] 78 45 (Mumbai - Trib.)

IT/ILT : Where assessee-company received certain amount from its wholly owned foreign subsidiary on account of buy-back of shares, since assessee had given ample justification of buy back price by pointing out NAV of investee company on date of buy-back, which was much lower than buy-back price, TPO was not justified in considering aforesaid transaction as sham and making addition of notional interest on amount in question

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