https://www.taxtmi.com/caselaws?id=801774 Paragraph 3.3(a) of CBDT Instruction No. 3/2016 permits a transfer-pricing reference in a case selected on non-transfer-pricing parameters only where the section 92E accountant's report was not filed or the relevant international transaction was not disclosed. Form 3CEB disclosed and quantified interest on fully and compulsorily convertible debentures, which was the transaction subjected to adjustment. Differences between the return and financial statements did not establish a separate undisclosed international transaction, and procedural steps could not replace the substantive preconditions for a reference. The transfer-pricing adjustment relating to disclosed debenture interest was deleted. en-us Mon, 28 Sep 2026 00:00:00 +0530 Tue, 27 Oct 2026 08:33:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801774 Paragraph 3.3(a) of CBDT Instruction No. 3/2016 permits a transfer-pricing reference in a case selected on non-transfer-pricing parameters only where the section 92E accountant's report was not filed or the relevant international transaction was not disclosed. Form 3CEB disclosed and quantified interest on fully and compulsorily convertible debentures, which was the transaction subjected to adjustment. Differences between the return and financial statements did not establish a separate undisclosed international transaction, and procedural steps could not replace the substantive preconditions for a reference. The transfer-pricing adjustment relating to disclosed debenture interest was deleted. Case-Laws Income Tax Mon, 28 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801774