https://www.taxtmi.com/caselaws?id=794053 A preference-share investment with an associated enterprise could not be re-characterised as a loan for transfer pricing purposes absent material showing sham, concealment, or other exceptional circumstances; notional interest therefore could not be imputed and the adjustment failed. Interest disallowance under section 36(1)(iii) was also unwarranted because the assessee had sufficient own funds to cover the advances to subsidiaries and related concerns, so the advances were presumed to have been made from those funds rather than borrowed money. Both additions were deleted in the assessee's favour. en-us Tue, 10 Mar 2026 00:00:00 +0530 Mon, 29 Jun 2026 10:14:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794053 A preference-share investment with an associated enterprise could not be re-characterised as a loan for transfer pricing purposes absent material showing sham, concealment, or other exceptional circumstances; notional interest therefore could not be imputed and the adjustment failed. Interest disallowance under section 36(1)(iii) was also unwarranted because the assessee had sufficient own funds to cover the advances to subsidiaries and related concerns, so the advances were presumed to have been made from those funds rather than borrowed money. Both additions were deleted in the assessee's favour. Case-Laws Income Tax Tue, 10 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794053