Monday, 13 July 2015

ITAT creates distinction between ‘quasi-capital’ and ‘loan’ for ALP computation

IT/ILT : It cannot be said that whenever any loan is in the nature of quasi-capital, the ALP for such capital shall be 'nil' rate of interest. Several types of debts, particularly long-term unsecured debts, and revenue participation investments could be termed as 'quasi-capital'. The comparable uncontrolled price of 'quasi-capital' loan could not be 'nil', unless it is only for at ransitory period and the de facto reward for this value of money is the opportunity for capital investment

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