https://www.taxtmi.com/caselaws?id=799274 Disallowance under section 40(a)(i) for payments to foreign related entities requires verification of the payments' nature, underlying arrangements, reimbursement and invoicing model, treaty taxability, and whether withholding tax under section 195 applies; absent this examination, fresh adjudication is required. For a debt-free assessee, a separate transfer-pricing adjustment for notional interest on overdue receivables from associated enterprises is unwarranted under the applicable Tribunal precedent and should be deleted. The withholding-tax issue remains subject to factual and legal determination, while the notional-interest adjustment is eliminated. en-us Wed, 28 Jan 2026 00:00:00 +0530 Sat, 19 Sep 2026 08:20:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799274 Disallowance under section 40(a)(i) for payments to foreign related entities requires verification of the payments' nature, underlying arrangements, reimbursement and invoicing model, treaty taxability, and whether withholding tax under section 195 applies; absent this examination, fresh adjudication is required. For a debt-free assessee, a separate transfer-pricing adjustment for notional interest on overdue receivables from associated enterprises is unwarranted under the applicable Tribunal precedent and should be deleted. The withholding-tax issue remains subject to factual and legal determination, while the notional-interest adjustment is eliminated. Case-Laws Income Tax Wed, 28 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799274