https://www.taxtmi.com/caselaws?id=271061 For a foreign currency loan to an associated enterprise, the relevant overseas lending rate applied rather than the Indian prime lending rate, so the transfer pricing adjustment was confined to the assessee's own suo motu figure. A corporate guarantee for an associated enterprise was benchmarked at 0.5%, and the higher adjustment was reduced. Adjustments linked to share premium and notional interest were held outside Chapter X because share issue proceeds are capital receipts and do not constitute income. Disallowance under section 14A was not sustainable without exempt income, and the AIR mismatch addition required fresh examination and proper reconciliation. en-us Wed, 04 Nov 2015 00:00:00 +0530 Wed, 30 Dec 2015 12:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=271061 For a foreign currency loan to an associated enterprise, the relevant overseas lending rate applied rather than the Indian prime lending rate, so the transfer pricing adjustment was confined to the assessee's own suo motu figure. A corporate guarantee for an associated enterprise was benchmarked at 0.5%, and the higher adjustment was reduced. Adjustments linked to share premium and notional interest were held outside Chapter X because share issue proceeds are capital receipts and do not constitute income. Disallowance under section 14A was not sustainable without exempt income, and the AIR mismatch addition required fresh examination and proper reconciliation. Case-Laws Income Tax Wed, 04 Nov 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=271061