https://www.taxtmi.com/highlights?id=103318 Negative liens over participating interests in oil and gas blocks and related receivables, created to secure associated enterprises' borrowings, are treated as international transactions where they restrict the asset-owning entity's ability to charge, borrow against, or expand using its operating assets. A lender's security interest may continue despite the borrower entities' bankruptcy. Arm's-length pricing must reflect the negative lien's factual character and resulting impairment of borrowing capacity; averaging bank-guarantee rates or applying loan-benchmarking approaches is not appropriate. The arm's-length price requires fresh determination under applicable transfer-pricing provisions. en-us Wed, 02 Sep 2026 08:30:15 +0530 Wed, 02 Sep 2026 08:30:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103318 Negative liens over participating interests in oil and gas blocks and related receivables, created to secure associated enterprises' borrowings, are treated as international transactions where they restrict the asset-owning entity's ability to charge, borrow against, or expand using its operating assets. A lender's security interest may continue despite the borrower entities' bankruptcy. Arm's-length pricing must reflect the negative lien's factual character and resulting impairment of borrowing capacity; averaging bank-guarantee rates or applying loan-benchmarking approaches is not appropriate. The arm's-length price requires fresh determination under applicable transfer-pricing provisions. Highlights Income Tax Wed, 02 Sep 2026 08:30:15 +0530 https://www.taxtmi.com/highlights?id=103318