https://www.taxtmi.com/highlights?id=101188 Subscription to and redemption of non-cumulative redeemable preference shares could not be re-characterised as an unsecured loan for transfer pricing purposes in the absence of material showing a sham or concealment of the real transaction; with only an opening balance and minor redemption, the notional interest adjustment was deleted. On advances to subsidiaries, the assessee's substantial own funds and interest-free funds exceeded the advances, so the presumption applied that the advances came from own funds rather than borrowed funds, and the interest disallowance was deleted. The Revenue's appeal was dismissed. en-us Mon, 29 Jun 2026 09:28:31 +0530 Mon, 29 Jun 2026 09:28:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=101188 Subscription to and redemption of non-cumulative redeemable preference shares could not be re-characterised as an unsecured loan for transfer pricing purposes in the absence of material showing a sham or concealment of the real transaction; with only an opening balance and minor redemption, the notional interest adjustment was deleted. On advances to subsidiaries, the assessee's substantial own funds and interest-free funds exceeded the advances, so the presumption applied that the advances came from own funds rather than borrowed funds, and the interest disallowance was deleted. The Revenue's appeal was dismissed. Highlights Income Tax Mon, 29 Jun 2026 09:28:31 +0530 https://www.taxtmi.com/highlights?id=101188