Where the character of payment is towards share application ...
Share Application Money as Capital Investment Not Subject to Arm's Length Price Adjustment if Nature Undisputed by Officer.
December 12, 2014
Case Laws Income Tax AT
Where the character of payment is towards share application money, thereby reflecting a capital investment, and the same not having been disputed by the TPO, such a transaction cannot be subject to an arm's length price adjustment under the plea of it being a transaction of lending or borrowing - AT
View Source