https://www.taxtmi.com/caselaws?id=790841 The transfer pricing adjustment imputing interest on the loan advanced to the German subsidiary was set aside because additional evidence showed the subsidiary had entered liquidation and the investment and loan had been written off. As the new material directly affected the sustainability of the interest adjustment, the matter was remitted for fresh adjudication by the Assessing Officer after granting the assessee an effective opportunity of hearing. The additional evidence was taken on record, and the substantive transfer pricing issue was left open for reconsideration. en-us Tue, 28 Apr 2026 00:00:00 +0530 Fri, 01 May 2026 10:14:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790841 The transfer pricing adjustment imputing interest on the loan advanced to the German subsidiary was set aside because additional evidence showed the subsidiary had entered liquidation and the investment and loan had been written off. As the new material directly affected the sustainability of the interest adjustment, the matter was remitted for fresh adjudication by the Assessing Officer after granting the assessee an effective opportunity of hearing. The additional evidence was taken on record, and the substantive transfer pricing issue was left open for reconsideration. Case-Laws Income Tax Tue, 28 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790841