https://www.taxtmi.com/caselaws?id=472357 Interest-free advances to wholly owned subsidiaries, used for overseas business expansion as owners' quasi-equity and not funded by domestic borrowings, were not benchmarked as ordinary loans for a notional-interest transfer-pricing adjustment; the adjustment was deleted. Corporate-guarantee pricing was restricted to 0.5%, reflecting an arm's-length rate materially lower than a bank-guarantee rate. A creditor's write-off supported an addition for remission or cessation of the related trading liability, while a separate alleged liability required verification of whether it remained outstanding in the taxpayer's books. Only the established write-off addition survived, subject to verification of the other liability. en-us Tue, 05 Nov 2024 00:00:00 +0530 Thu, 08 Oct 2026 20:44:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472357 Interest-free advances to wholly owned subsidiaries, used for overseas business expansion as owners' quasi-equity and not funded by domestic borrowings, were not benchmarked as ordinary loans for a notional-interest transfer-pricing adjustment; the adjustment was deleted. Corporate-guarantee pricing was restricted to 0.5%, reflecting an arm's-length rate materially lower than a bank-guarantee rate. A creditor's write-off supported an addition for remission or cessation of the related trading liability, while a separate alleged liability required verification of whether it remained outstanding in the taxpayer's books. Only the established write-off addition survived, subject to verification of the other liability. Case-Laws Income Tax Tue, 05 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472357