https://www.taxtmi.com/caselaws?id=253528 Interest on loans advanced to associated enterprises was treated as an international transaction requiring arm's length benchmarking; LIBOR plus a markup was accepted as the appropriate base, and the treaty argument on unpaid interest did not prevent transfer pricing adjustment. Share application money remitted to an overseas subsidiary was held to be capital in character and not ordinarily re-characterisable as a loan, though abnormal delay in allotment may still require arm's length examination on the facts. Additional equity infusion had to be tested on proper arm's length valuation principles, but a further notional interest adjustment on the same infusion was impermissible as a secondary transfer pricing adjustment. en-us Fri, 22 Aug 2014 00:00:00 +0530 Thu, 27 Nov 2014 06:33:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253528 Interest on loans advanced to associated enterprises was treated as an international transaction requiring arm's length benchmarking; LIBOR plus a markup was accepted as the appropriate base, and the treaty argument on unpaid interest did not prevent transfer pricing adjustment. Share application money remitted to an overseas subsidiary was held to be capital in character and not ordinarily re-characterisable as a loan, though abnormal delay in allotment may still require arm's length examination on the facts. Additional equity infusion had to be tested on proper arm's length valuation principles, but a further notional interest adjustment on the same infusion was impermissible as a secondary transfer pricing adjustment. Case-Laws Income Tax Fri, 22 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253528