https://www.taxtmi.com/caselaws?id=790226 A transfer pricing adjustment on interest-free related-party financing was treated as unsustainable where the company had not commenced business, had capitalised all expenditure to capital work-in-progress, and had no taxable income for the year. On those facts, the premise of profit shifting to associated enterprises did not survive because there was no business profit or distributable income to benchmark. The note further states that section 115BAB has relevance only where income exists for computation, and in the absence of income there was no basis to sustain such an adjustment. Following a coordinate bench decision on materially similar facts, the addition was deleted and the issue was resolved in favour of the assessee. 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 A transfer pricing adjustment on interest-free related-party financing was treated as unsustainable where the company had not commenced business, had capitalised all expenditure to capital work-in-progress, and had no taxable income for the year. On those facts, the premise of profit shifting to associated enterprises did not survive because there was no business profit or distributable income to benchmark. The note further states that section 115BAB has relevance only where income exists for computation, and in the absence of income there was no basis to sustain such an adjustment. Following a coordinate bench decision on materially similar facts, the addition was deleted and the issue was resolved in favour of the assessee. Case-Laws Income Tax Mon, 05 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790226