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2014 (12) TMI 1204 - AT - Income TaxTransfer pricing adjustment - transaction of issue of equity shares - Held that:- The capital receipts received by the assessee on issue of equity shares to its holding company cannot be considered income. Ajustment made by the AO on account of ‘share premium’ and ‘interest charged on account of under charged premium amount cannot be endorsed. We also hold that TP provisions are not applicable to such transaction. See Vodafone India Services Private Limited case [2014 (10) TMI 278 - BOMBAY HIGH COURT] - Decided in favour of the assessee.
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