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ITAT dismissed the Transfer Pricing Officer's notional interest adjustment, holding that intercompany receipts constituted settlement of intra-group receivables leaving no outstanding claim at year-end, so no notional interest was chargeable. Marketing expenses and non-transactional bank charges were excluded from the assessee's PLI computation; operational bank charges supported by segmental accounts may be included. The assessee's artificial segmentation to minimize PLI was rejected. Five contested comparables are to be included after FAR verification, while several others (identified as functionally dissimilar) are excluded. TPO must revisit benchmarking and compute ALP accordingly. The AO is directed to apply corporate tax under s.115BBA after necessary verification. The appeal is partly allowed.
ITAT dismissed the Transfer Pricing Officer's notional interest adjustment, holding that intercompany receipts constituted settlement of intra-group receivables leaving no outstanding claim at year-end, so no notional interest was chargeable. Marketing expenses and non-transactional bank charges were excluded from the assessee's PLI computation; operational bank charges supported by segmental accounts may be included. The assessee's artificial segmentation to minimize PLI was rejected. Five contested comparables are to be included after FAR verification, while several others (identified as functionally dissimilar) are excluded. TPO must revisit benchmarking and compute ALP accordingly. The AO is directed to apply corporate tax under s.115BBA after necessary verification. The appeal is partly allowed.
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