https://www.taxtmi.com/caselaws?id=469675 Redeemable preference share investments in an associated enterprise cannot be re-characterised as interest-free loans for transfer pricing purposes without material establishing a sham or fictitious arrangement; consequently, notional interest cannot be imputed merely on the outstanding investment balance. Interest expenditure is not disallowable under section 36(1)(iii) where sufficient interest-free own funds coexist with borrowings and no direct nexus establishes that advances to related concerns were funded from borrowed money. In that circumstance, the advances are presumed to have been made from own funds. The substantive additions for notional interest and interest disallowance were deleted, while unpressed or consequential issues remained unaffected. en-us Fri, 21 Jul 2023 00:00:00 +0530 Sat, 27 Jun 2026 14:00:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469675 Redeemable preference share investments in an associated enterprise cannot be re-characterised as interest-free loans for transfer pricing purposes without material establishing a sham or fictitious arrangement; consequently, notional interest cannot be imputed merely on the outstanding investment balance. Interest expenditure is not disallowable under section 36(1)(iii) where sufficient interest-free own funds coexist with borrowings and no direct nexus establishes that advances to related concerns were funded from borrowed money. In that circumstance, the advances are presumed to have been made from own funds. The substantive additions for notional interest and interest disallowance were deleted, while unpressed or consequential issues remained unaffected. Case-Laws Income Tax Fri, 21 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469675