https://www.taxtmi.com/caselaws?id=796412 Foreign-currency intra-group loans are benchmarked against the market rate for the repayment currency, while corporate guarantees are international transactions requiring a corporate-guarantee benchmark rather than bank-guarantee pricing. Overseas associated enterprises operating across different economic zones and currencies may not be suitable tested parties for BPO benchmarking; comparable selection and functional analysis require fresh evaluation. Separate STPI centres may qualify as distinct section 10A undertakings where they have independent identity, capital, workforce, infrastructure, output and profits, regardless of common licences. Export-turnover exclusions must correspondingly reduce total turnover. The notes also address exempt-income disallowance, deductibility of ESOP and hedging losses, treaty-based dividend tax relief, and verification of tax credits and eligible-unit investment income. en-us Thu, 30 Jul 2026 00:00:00 +0530 Wed, 05 Aug 2026 08:48:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796412 Foreign-currency intra-group loans are benchmarked against the market rate for the repayment currency, while corporate guarantees are international transactions requiring a corporate-guarantee benchmark rather than bank-guarantee pricing. Overseas associated enterprises operating across different economic zones and currencies may not be suitable tested parties for BPO benchmarking; comparable selection and functional analysis require fresh evaluation. Separate STPI centres may qualify as distinct section 10A undertakings where they have independent identity, capital, workforce, infrastructure, output and profits, regardless of common licences. Export-turnover exclusions must correspondingly reduce total turnover. The notes also address exempt-income disallowance, deductibility of ESOP and hedging losses, treaty-based dividend tax relief, and verification of tax credits and eligible-unit investment income. Case-Laws Income Tax Thu, 30 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796412