https://www.taxtmi.com/caselaws?id=796412 Transfer-pricing analysis requires foreign-currency intra-group loans to be benchmarked against the market rate for the repayment currency; GBP LIBOR plus an appropriate margin supported arm's-length pricing where the charged rate exceeded that benchmark. Corporate guarantees constitute international transactions, but a corporate-guarantee rate rather than bank-guarantee pricing applies. Overseas associated enterprises operating across different economic conditions could not jointly serve as BPO tested parties, requiring fresh functional, asset and risk-based benchmarking. Separate STPI centres may qualify as independent section 10A undertakings if they have distinct capital, workforce, infrastructure, output and profits. Export-turnover exclusions must correspondingly reduce total turnover, while investment income deductions depend on eligible units' internal accruals and verification. 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 Transfer-pricing analysis requires foreign-currency intra-group loans to be benchmarked against the market rate for the repayment currency; GBP LIBOR plus an appropriate margin supported arm's-length pricing where the charged rate exceeded that benchmark. Corporate guarantees constitute international transactions, but a corporate-guarantee rate rather than bank-guarantee pricing applies. Overseas associated enterprises operating across different economic conditions could not jointly serve as BPO tested parties, requiring fresh functional, asset and risk-based benchmarking. Separate STPI centres may qualify as independent section 10A undertakings if they have distinct capital, workforce, infrastructure, output and profits. Export-turnover exclusions must correspondingly reduce total turnover, while investment income deductions depend on eligible units' internal accruals and verification. Case-Laws Income Tax Thu, 30 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796412