TMI BlogTP adjustment - disallowance of interest - characterizing the share application money to associate...TP adjustment - disallowance of interest - characterizing the share application money to associate enterprises as interest free advance - onus is upon the AO to prove that it is an international transaction of capital financing - Such a presumption cannot change the character of transaction ..... X X X X Extracts X X X X X X X X Extracts X X X X
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