https://www.taxtmi.com/caselaws?id=798832 Transfer-pricing analysis of interest on non-convertible debentures requires comparability filters supported by reliable data and an economic rationale. A minimum-tenure threshold cannot be treated as appropriate merely by assertion where comparable evidence does not show a consistent relationship between tenure and coupon rate. For interest-limitation purposes, the section 94B computation is confined to interest on debt issued by a non-resident associated enterprise. Interest paid to non-associated enterprises must therefore be excluded, and the computation must reflect any transfer-pricing adjustment deletion and existing voluntary disallowance to avoid duplicate disallowance. en-us Wed, 09 Sep 2026 00:00:00 +0530 Sat, 12 Sep 2026 08:41:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798832 Transfer-pricing analysis of interest on non-convertible debentures requires comparability filters supported by reliable data and an economic rationale. A minimum-tenure threshold cannot be treated as appropriate merely by assertion where comparable evidence does not show a consistent relationship between tenure and coupon rate. For interest-limitation purposes, the section 94B computation is confined to interest on debt issued by a non-resident associated enterprise. Interest paid to non-associated enterprises must therefore be excluded, and the computation must reflect any transfer-pricing adjustment deletion and existing voluntary disallowance to avoid duplicate disallowance. Case-Laws Income Tax Wed, 09 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798832