Section 10(1)(hA) of ITA

(hA)  any amount received by or accrued to the holder of a debt-

(i)      if the holder of that debt is a company that forms part of the same group of companies, as defined in section 41, as the issuer of that debt; and

(ii)     to the extent that the amount is attributable to any amount of interest as defined in section 23K(1) that is not deductible as a result of the application of section 23K;