https://www.taxtmi.com/caselaws?id=469733 Transfer pricing on interest receivable from associated enterprises was examined in the context of repeated loan amendments, extended tenure and deferred interest, leading the Tribunal to treat the arrangement as a long-term loan for benchmarking purposes, while remanding the matter because no proper comparable long-term loan data had been used. Section 14A disallowance was confined to investments that actually yielded exempt income, and no disallowance survived where no exempt income was earned; the MAT adjustment under section 115JB was also deleted. By contrast, section 80IA deduction was computed on the eligible business as a whole under section 80IA(5), not on a unit-wise basis. Claims for write-off of stores, duplicate gratuity and feasibility report expenditure were remanded or partly rejected, with feasibility expenditure treated as capital in nature. en-us Wed, 26 Mar 2025 00:00:00 +0530 Wed, 01 Jul 2026 20:42:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469733 Transfer pricing on interest receivable from associated enterprises was examined in the context of repeated loan amendments, extended tenure and deferred interest, leading the Tribunal to treat the arrangement as a long-term loan for benchmarking purposes, while remanding the matter because no proper comparable long-term loan data had been used. Section 14A disallowance was confined to investments that actually yielded exempt income, and no disallowance survived where no exempt income was earned; the MAT adjustment under section 115JB was also deleted. By contrast, section 80IA deduction was computed on the eligible business as a whole under section 80IA(5), not on a unit-wise basis. Claims for write-off of stores, duplicate gratuity and feasibility report expenditure were remanded or partly rejected, with feasibility expenditure treated as capital in nature. Case-Laws Income Tax Wed, 26 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469733