Preference share investment recharacterised as loan for transfer pricing, DRP/TPO action affirmed and interest benchmarked.

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....Transfer pricing issue: preference share investment was treated as a disguised loan and recharacterised for TP purposes on substance-over-form grounds; DRP/TPO conclusion was affirmed and interest benchmarked accordingly. Disallowance under exempt-income allocation: the assessee's suo motu ad hoc apportionment of employee and overhead costs was rejected as unsupported. Interest disallowance against investments was denied where interest free funds exceeded investments; administrative disallowance to be recomputed per relevant precedent. An additional ground on cost attribution for captive steam was refused; AO correctly attributed full plant cost to electricity, eliminating the 80 IA deduction. Interest deduction for acquisition of control d.........