https://www.taxtmi.com/highlights?id=103319 Commercially genuine exclusivity payments, transition-fee reimbursements and upfront discounts made to associated enterprises cannot be disregarded merely because their commercial structure is unusual or their expediency is questioned. Arm's length pricing cannot be fixed at nil without applying a prescribed transfer-pricing method; where the underlying primary adjustment fails, consequential notional interest also fails. Secondary-adjustment provisions do not apply to primary adjustments preceding 1 April 2016. Interest on a foreign-currency associated-enterprise loan is benchmarked at LIBOR plus 80 basis points. For exempt-income disallowance, only income-yielding investments are relevant and sufficient own interest-free funds preclude in..... 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=103319 Commercially genuine exclusivity payments, transition-fee reimbursements and upfront discounts made to associated enterprises cannot be disregarded merely because their commercial structure is unusual or their expediency is questioned. Arm's length pricing cannot be fixed at nil without applying a prescribed transfer-pricing method; where the underlying primary adjustment fails, consequential notional interest also fails. Secondary-adjustment provisions do not apply to primary adjustments preceding 1 April 2016. Interest on a foreign-currency associated-enterprise loan is benchmarked at LIBOR plus 80 basis points. For exempt-income disallowance, only income-yielding investments are relevant and sufficient own interest-free funds preclude in..... Highlights Income Tax Wed, 02 Sep 2026 08:30:15 +0530 https://www.taxtmi.com/highlights?id=103319