Omission of clause (i) of section 92BA rendered transfer-pricing...

Omission of clause (i) of section 92BA rendered transfer-pricing references and consequential adjustments for covered specified domestic transactions unsustainable, making the alternative dispute over the most appropriate method academic. Mark-to-market losses from equity and currency futures remained allowable because no material factual or legal distinction from the earlier decision was established. Where audited statements showed own funds exceeded investments generating exempt income, no interest disallowance applied. Administrative expenditure disallowance was confined to investments relevant to exempt income after crediting the taxpayer's self-disallowance. The Revenue's appeals were dismissed, while the taxpayer's alternate challenge did not survive.