Delay In Allotting Shares No Basis To Treat Share Application Money In Hands Of Overseas AE As 'Loan': Mumbai ITAT Deletes Notional Interest

The Mumbai ITAT held that delayed allotment of shares doesn’t justify treating share application money as a loan. The tribunal deleted the notional interest, asserting that foreign associated enterprises shouldn’t be treated as creditors just because shares are issued late. This ruling provides relief to overseas entities from unnecessary tax burdens on notional income, affirming a fair approach in share allotment matters.