https://www.taxtmi.com/caselaws?id=798095 Transfer-pricing adjustments cannot recharacterise commercially substantiated exclusivity payments, transition-cost reimbursements or upfront discounts as loans merely because of their unconventional form; arm's-length pricing must use a prescribed benchmarking method. Secondary adjustments are unavailable for assessment years commencing before 1 April 2016. Foreign-currency associated-enterprise loans should use a currency-specific benchmark, with LIBOR plus appropriate risk adjustment. Exempt-income disallowance requires objective satisfaction from the accounts; only income-yielding investments count, and sufficient own interest-free funds negate interest disallowance. Export-turnover exclusions cannot include costs never included in that turnover. TDS credit depends on verification of certificates and tax deposit. Education-cess deduction under section 37(1) is unavailable under the retrospective Finance Act, 2022 amendment. en-us Mon, 24 Aug 2026 00:00:00 +0530 Wed, 02 Sep 2026 08:30:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798095 Transfer-pricing adjustments cannot recharacterise commercially substantiated exclusivity payments, transition-cost reimbursements or upfront discounts as loans merely because of their unconventional form; arm's-length pricing must use a prescribed benchmarking method. Secondary adjustments are unavailable for assessment years commencing before 1 April 2016. Foreign-currency associated-enterprise loans should use a currency-specific benchmark, with LIBOR plus appropriate risk adjustment. Exempt-income disallowance requires objective satisfaction from the accounts; only income-yielding investments count, and sufficient own interest-free funds negate interest disallowance. Export-turnover exclusions cannot include costs never included in that turnover. TDS credit depends on verification of certificates and tax deposit. Education-cess deduction under section 37(1) is unavailable under the retrospective Finance Act, 2022 amendment. Case-Laws Income Tax Mon, 24 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798095