The ITAT directed de novo verification by the AO/TPO of transfer...

The ITAT directed de novo verification by the AO/TPO of transfer pricing segmentation: the taxpayer must reconcile its segmental audit report with audited financial statements, disclose segmental revenues and explain employee-cost variances; grounds 2-5 are allowed for statistical purposes. For benchmarking trade receivables from foreign AEs, the Tribunal prescribed LIBOR + 200 bps and allowed a 60-day interest-free credit period. The s.14A disallowance of Rs.2,00,990 was deleted. CSR expenditures were held non-deductible under s.37(1) and the disallowance upheld. Claims of prior-period expenses and discrepancies vis-à-vis Form 26AS were remitted to the AO for factual verification. The limitation issue was reserved to the AO to be addressed in light of the pending SC determination.