https://www.taxtmi.com/highlights?id=104304 Internal comparable pricing of interest on compulsorily convertible debentures applied where subscriptions under the same agreement carried identical material terms and no relevant change was established. The comparable supported acceptance of the 15% interest rate as arm's length and deletion of the transfer-pricing adjustment based on treating the debentures as equity. Interest disallowance for payments to a foreign associated enterprise required factual verification of the correct associated-enterprise interest. Set-off of brought-forward business losses likewise required verification of quantum, availability, and appellate effect. A challenge solely to initiation of penalty proceedings was premature. en-us Tue, 29 Sep 2026 08:34:54 +0530 Tue, 29 Sep 2026 08:34:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=104304 Internal comparable pricing of interest on compulsorily convertible debentures applied where subscriptions under the same agreement carried identical material terms and no relevant change was established. The comparable supported acceptance of the 15% interest rate as arm's length and deletion of the transfer-pricing adjustment based on treating the debentures as equity. Interest disallowance for payments to a foreign associated enterprise required factual verification of the correct associated-enterprise interest. Set-off of brought-forward business losses likewise required verification of quantum, availability, and appellate effect. A challenge solely to initiation of penalty proceedings was premature. Highlights Income Tax Tue, 29 Sep 2026 08:34:54 +0530 https://www.taxtmi.com/highlights?id=104304