<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>Transfer pricing interest, guarantee fee, and exempt-income disallowance relief upheld on consistency and prior precedent</title>
    <link>https://www.taxtmi.com/highlights?id=101098</link>
    <description>Transfer pricing on loans to associated enterprises was confined to the LIBOR-based rate already accepted in earlier precedent, so no further interest adjustment was warranted. Corporate guarantee commission was retained at 0.35% on consistency with earlier years and the interest-saved approach. Deduction for rail and water systems as infrastructure facility under section 80-IA was allowed because the earlier orders had attained finality. The section 14A disallowance was restricted: interest disallowance was deleted where interest-free funds exceeded investments, and administrative expenditure was computed only on investments yielding exempt income, with corresponding book-profit relief. The gain on prepayment of sales tax deferral was treated as capital receipt, and the write-back of project creditors was not taxable under section 28(iv).</description>
    <language>en-us</language>
    <pubDate>Thu, 25 Jun 2026 08:27:37 +0530</pubDate>
    <lastBuildDate>Thu, 25 Jun 2026 08:27:40 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=908538" rel="self" type="application/rss+xml"/>
    <item>
      <title>Transfer pricing interest, guarantee fee, and exempt-income disallowance relief upheld on consistency and prior precedent</title>
      <link>https://www.taxtmi.com/highlights?id=101098</link>
      <description>Transfer pricing on loans to associated enterprises was confined to the LIBOR-based rate already accepted in earlier precedent, so no further interest adjustment was warranted. Corporate guarantee commission was retained at 0.35% on consistency with earlier years and the interest-saved approach. Deduction for rail and water systems as infrastructure facility under section 80-IA was allowed because the earlier orders had attained finality. The section 14A disallowance was restricted: interest disallowance was deleted where interest-free funds exceeded investments, and administrative expenditure was computed only on investments yielding exempt income, with corresponding book-profit relief. The gain on prepayment of sales tax deferral was treated as capital receipt, and the write-back of project creditors was not taxable under section 28(iv).</description>
      <category>Highlights</category>
      <law>Income Tax</law>
      <pubDate>Thu, 25 Jun 2026 08:27:37 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/highlights?id=101098</guid>
    </item>
  </channel>
</rss>