https://www.taxtmi.com/caselaws?id=800641 Transfer-pricing rules do not support imputed interest on OFCD investments or associated-enterprise balances where income has not accrued in real terms, recovery is commercially improbable, and amounts are irrecoverable; OFCDs with conversion rights may be quasi-equity, while corporate-guarantee payments are not necessarily loans. Inventory must be valued at cost or net realisable value, whichever is lower, and a consistently applied net realisable value method cannot be replaced by average purchase cost without evidence that it is incorrect. For AY 2015-16, absent an enabling provision, fair market value could not replace actual share-transfer consideration in computing capital loss. Parent corporate guarantees are not comparable to bank guarantees; a 0.5% commission benchmark was treated as appropriate on the stated facts. en-us Mon, 27 Apr 2026 00:00:00 +0530 Fri, 09 Oct 2026 08:30:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800641 Transfer-pricing rules do not support imputed interest on OFCD investments or associated-enterprise balances where income has not accrued in real terms, recovery is commercially improbable, and amounts are irrecoverable; OFCDs with conversion rights may be quasi-equity, while corporate-guarantee payments are not necessarily loans. Inventory must be valued at cost or net realisable value, whichever is lower, and a consistently applied net realisable value method cannot be replaced by average purchase cost without evidence that it is incorrect. For AY 2015-16, absent an enabling provision, fair market value could not replace actual share-transfer consideration in computing capital loss. Parent corporate guarantees are not comparable to bank guarantees; a 0.5% commission benchmark was treated as appropriate on the stated facts. Case-Laws Income Tax Mon, 27 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800641