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ITAT remitted issues to the AO/TPO, directing the assessee to substantiate selection of the foreign AE as tested party with requisite financial data; AO/TPO to examine whether the tested party yields a reliable ALP, afford the assessee hearing, and determine ALP for the trading of finished goods. Separate ALP exercises are directed for trading of raw materials/API with the AE as tested party; earlier comparable analyses may survive only if AO/TPO so finds. The Tribunal upheld treatment of capitalised R&D not shown amortised as operating expense and rejected inclusion of loss on sale/disposal of PPE in operating expenses, directing its exclusion. Overdue receivables from AE are held international transactions; notional interest to be computed by the TPO at LIBOR plus applicable markup in accordance with Rule 10CB.
ITAT remitted issues to the AO/TPO, directing the assessee to substantiate selection of the foreign AE as tested party with requisite financial data; AO/TPO to examine whether the tested party yields a reliable ALP, afford the assessee hearing, and determine ALP for the trading of finished goods. Separate ALP exercises are directed for trading of raw materials/API with the AE as tested party; earlier comparable analyses may survive only if AO/TPO so finds. The Tribunal upheld treatment of capitalised R&D not shown amortised as operating expense and rejected inclusion of loss on sale/disposal of PPE in operating expenses, directing its exclusion. Overdue receivables from AE are held international transactions; notional interest to be computed by the TPO at LIBOR plus applicable markup in accordance with Rule 10CB.
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