Facts
a)
Assessee, a foreign company, granted loan of € 90,00,000 to its subsidiary in India.
b)
It sold the aforesaid debt for € 7,31,000 as its subsidiary
ran into serious financial crisis. The assessee claimed short term capital loss
on this transaction of sale of debt.
c)
Assessing Officer (AO) disallowed claim of assessee on
ground that loan couldn’t be treated as capital asset under Section 2(14).
d)
CIT(A) confirmed the order of AO. Aggrieved assessee filed
the instant appeal before the tribunal.
