https://www.taxtmi.com/caselaws?id=793961 Transfer pricing adjustments for subscription and redemption of preference shares and a corporate guarantee were treated as covered by earlier decisions in the assessee's own case, and no substantial question of law arose. The court noted that, absent material showing a sham or exceptional circumstances, the transfer pricing officer could not re-characterise the preference share transaction as a loan and impute notional interest. On the corporate guarantee, the distinction from a bank guarantee and the Tribunal's lower commission rate were sustained. For interest disallowance under Section 36(1)(iii), the assessee's sufficient own funds created a presumption that advances to sister concerns and subsidiaries came from those funds, so no disallowance was warranted. en-us Fri, 19 Jun 2026 00:00:00 +0530 Fri, 26 Jun 2026 07:07:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793961 Transfer pricing adjustments for subscription and redemption of preference shares and a corporate guarantee were treated as covered by earlier decisions in the assessee's own case, and no substantial question of law arose. The court noted that, absent material showing a sham or exceptional circumstances, the transfer pricing officer could not re-characterise the preference share transaction as a loan and impute notional interest. On the corporate guarantee, the distinction from a bank guarantee and the Tribunal's lower commission rate were sustained. For interest disallowance under Section 36(1)(iii), the assessee's sufficient own funds created a presumption that advances to sister concerns and subsidiaries came from those funds, so no disallowance was warranted. Case-Laws Income Tax Fri, 19 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793961