https://www.taxtmi.com/caselaws?id=797469 Transfer pricing treatment of zero-coupon non-convertible debentures must remain consistent where the contractual terms, material facts and associated-enterprise transaction are unchanged. Debentures carrying no periodic interest but providing a holding-period-linked redemption premium had previously been accepted at arm's length without adjustment. Imputing notional interest on a later closing balance that included the earlier subscription effectively reversed that accepted treatment without recourse to permissible statutory proceedings. Although strict res judicata does not apply to assessment proceedings, consistency is required on unchanged facts. The notional-interest adjustment was therefore deleted. en-us Tue, 11 Aug 2026 00:00:00 +0530 Sat, 22 Aug 2026 10:33:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797469 Transfer pricing treatment of zero-coupon non-convertible debentures must remain consistent where the contractual terms, material facts and associated-enterprise transaction are unchanged. Debentures carrying no periodic interest but providing a holding-period-linked redemption premium had previously been accepted at arm's length without adjustment. Imputing notional interest on a later closing balance that included the earlier subscription effectively reversed that accepted treatment without recourse to permissible statutory proceedings. Although strict res judicata does not apply to assessment proceedings, consistency is required on unchanged facts. The notional-interest adjustment was therefore deleted. Case-Laws Income Tax Tue, 11 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797469