https://www.taxtmi.com/caselaws?id=470829 Associated-enterprise status under Section 92A(2)(c) is foundational to transfer-pricing adjustment of interest on non-convertible debentures and to the interest-limitation disallowance under Section 94B. A revised Form 3CEB filed before the transfer-pricing order identified only one lender as a deemed associated enterprise under the loan-to-assets threshold; Section 92CA(3) prescribes no time limit for such revision. The taxpayer must produce cogent evidence that the remaining lenders were independent enterprises. Transfer-pricing and Section 94B computations require fresh determination after establishing each lender's associated-enterprise status. en-us Wed, 26 Mar 2025 00:00:00 +0530 Mon, 10 Aug 2026 21:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470829 Associated-enterprise status under Section 92A(2)(c) is foundational to transfer-pricing adjustment of interest on non-convertible debentures and to the interest-limitation disallowance under Section 94B. A revised Form 3CEB filed before the transfer-pricing order identified only one lender as a deemed associated enterprise under the loan-to-assets threshold; Section 92CA(3) prescribes no time limit for such revision. The taxpayer must produce cogent evidence that the remaining lenders were independent enterprises. Transfer-pricing and Section 94B computations require fresh determination after establishing each lender's associated-enterprise status. Case-Laws Income Tax Wed, 26 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470829