https://www.taxtmi.com/caselaws?id=790226 Transfer pricing adjustment on interest-free lending to associated enterprises is unsustainable where the company had not commenced business, earned no taxable income or business profit, and capitalised expenditure to capital work-in-progress. Without taxable income or distributable profit, the premise that profits were shifted through related-party financing does not arise. The concessional tax regime for eligible domestic companies becomes relevant only where income exists for computation and cannot independently support such an adjustment. On materially similar group-company facts, the adjustment was deleted and the appeal succeeded. en-us Mon, 05 Jan 2026 00:00:00 +0530 Wed, 22 Apr 2026 08:47:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790226 Transfer pricing adjustment on interest-free lending to associated enterprises is unsustainable where the company had not commenced business, earned no taxable income or business profit, and capitalised expenditure to capital work-in-progress. Without taxable income or distributable profit, the premise that profits were shifted through related-party financing does not arise. The concessional tax regime for eligible domestic companies becomes relevant only where income exists for computation and cannot independently support such an adjustment. On materially similar group-company facts, the adjustment was deleted and the appeal succeeded. Case-Laws Income Tax Mon, 05 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790226