Transfer pricing on quasi-equity funding cannot create taxable interest where recovery is uncertain and no real income accrues.

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....Transfer-pricing principles preclude notional interest on quasi-equity OFCDs or unrecoverable associated-enterprise funding where recovery is uncertain and no real income accrues; payment under an invoked guarantee is not necessarily a lending transaction. Parent-company guarantees require arm's-length treatment distinct from bank guarantees. Inventory may be valued at the lower of cost and net realisable value where a consistently applied method and adverse market conditions support the valuation. Actual share-transfer consideration could not be replaced with fair market value to deny capital losses before the applicable substitution provision took effect. Foreign-exchange loss, income reconciliation, depreciation set-off and TDS credit require factual verification, including whether corresponding income was taxed.....