https://www.taxtmi.com/caselaws?id=470133 Only investments yielding exempt income should be included when computing expenditure disallowance under the prescribed method; investments in foreign subsidiaries generating taxable dividends should be excluded, and the disallowance should not exceed exempt income. The text further states that transfer-pricing rules do not permit a genuine share subscription or acquisition to be recharacterised as a loan merely because the share premium is considered excessive. A notional-interest adjustment requires income from the transaction or exceptional material showing that its apparent capital character is not genuine. en-us Mon, 17 Mar 2025 00:00:00 +0530 Thu, 16 Jul 2026 19:02:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470133 Only investments yielding exempt income should be included when computing expenditure disallowance under the prescribed method; investments in foreign subsidiaries generating taxable dividends should be excluded, and the disallowance should not exceed exempt income. The text further states that transfer-pricing rules do not permit a genuine share subscription or acquisition to be recharacterised as a loan merely because the share premium is considered excessive. A notional-interest adjustment requires income from the transaction or exceptional material showing that its apparent capital character is not genuine. Case-Laws Income Tax Mon, 17 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470133