In transfer pricing comparability, the Tribunal held that...

In transfer pricing comparability, the Tribunal held that working capital differences materially affect TNMM and that the freight forwarding segment required working capital adjustment; it also held that a comparable cannot be excluded merely because its statements do not expressly disclose related party transactions, absent material showing significant related party influence. The TPO was directed to grant the adjustment and include AP Logistics and Dimension Logistics. On corporate overhead charges, ALP could not be set at nil under CUP without benchmarking, so the issue was remitted for fresh examination with evidence. For notional interest on trade receivables, the Tribunal held that a debt-free company with no interest cost did not warrant a separate adjustment, and the addition was deleted for both years.

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