https://www.taxtmi.com/highlights?id=103694 Arm's-length pricing of interest on 30-year non-convertible debentures cannot rest on an unsupported minimum-tenure filter under the comparable uncontrolled price method, particularly where tenure does not uniformly determine coupon rates; the transfer-pricing adjustment was deleted. Interest limitation for debt payable to non-resident associated enterprises must exclude interest paid to non-associated enterprises and prevent duplicate disallowance of interest already affected by transfer pricing; recomputation and consequential relief were directed. Classification of assessment adjustments under the appropriate head of income requires verification of the computation and records. A challenge to penalty initiation is premature where no final penalty order is under appeal. en-us Sat, 12 Sep 2026 08:41:33 +0530 Sat, 12 Sep 2026 08:41:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103694 Arm's-length pricing of interest on 30-year non-convertible debentures cannot rest on an unsupported minimum-tenure filter under the comparable uncontrolled price method, particularly where tenure does not uniformly determine coupon rates; the transfer-pricing adjustment was deleted. Interest limitation for debt payable to non-resident associated enterprises must exclude interest paid to non-associated enterprises and prevent duplicate disallowance of interest already affected by transfer pricing; recomputation and consequential relief were directed. Classification of assessment adjustments under the appropriate head of income requires verification of the computation and records. A challenge to penalty initiation is premature where no final penalty order is under appeal. Highlights Income Tax Sat, 12 Sep 2026 08:41:33 +0530 https://www.taxtmi.com/highlights?id=103694