https://www.taxtmi.com/caselaws?id=789038 Transfer pricing adjustment on interest for loans advanced to wholly owned subsidiaries was rejected because the subsidiaries were under the assessee's control, the unsecured nature of the advances did not by itself show higher risk, and the interest rates had been accepted in earlier years with no adjustment in later years on the same loans. On those facts, imputing a higher arm's length return was unjustified, and the disallowance of interest could not be sustained. The assessee's ground was allowed. en-us Wed, 25 Mar 2026 00:00:00 +0530 Thu, 02 Apr 2026 08:50:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789038 Transfer pricing adjustment on interest for loans advanced to wholly owned subsidiaries was rejected because the subsidiaries were under the assessee's control, the unsecured nature of the advances did not by itself show higher risk, and the interest rates had been accepted in earlier years with no adjustment in later years on the same loans. On those facts, imputing a higher arm's length return was unjustified, and the disallowance of interest could not be sustained. The assessee's ground was allowed. Case-Laws Income Tax Wed, 25 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789038