Comparable uncontrolled price method requires an actual...

Comparable uncontrolled price method requires an actual uncontrolled transaction adjusted for material differences; bank lending rates with notional risk premiums and controlled related-party loans cannot serve as comparables. Same-year uncontrolled borrowings supported deletion of the transfer-pricing adjustment. Where interest-free own funds exceed investments, mixed-fund investments are presumed funded from own funds unless rebutted, deleting the Rule 8D interest disallowance. Administrative expenditure disallowance relating to exempt agricultural income was sustained because the assessing authority recorded dissatisfaction and the amount remained within exempt income. Interest on advances may be disallowed only upon proof that borrowed funds were diverted; absent that nexus, the interest disallowance was deleted.