https://www.taxtmi.com/caselaws?id=800889 Arm's-length benchmarking of interest on debt instruments issued to an associated enterprise requires reliable comparability analysis of debt currency, borrower creditworthiness and market conditions; the transfer-pricing adjustment was deleted because no factual basis displaced the accepted methodology. Rule 8D may be invoked only after objective, account-based dissatisfaction under section 14A(2); generic references to administrative and employee costs did not satisfy that precondition, restricting disallowance to the voluntary amount. A notional Rule 8D disallowance cannot automatically support an Explanation 1 clause (f) adjustment to book profit under section 115JB, so the corresponding addition was deleted. en-us Wed, 23 Sep 2026 00:00:00 +0530 Tue, 13 Oct 2026 07:21:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800889 Arm's-length benchmarking of interest on debt instruments issued to an associated enterprise requires reliable comparability analysis of debt currency, borrower creditworthiness and market conditions; the transfer-pricing adjustment was deleted because no factual basis displaced the accepted methodology. Rule 8D may be invoked only after objective, account-based dissatisfaction under section 14A(2); generic references to administrative and employee costs did not satisfy that precondition, restricting disallowance to the voluntary amount. A notional Rule 8D disallowance cannot automatically support an Explanation 1 clause (f) adjustment to book profit under section 115JB, so the corresponding addition was deleted. Case-Laws Income Tax Wed, 23 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800889