https://www.taxtmi.com/caselaws?id=311256 ITAT Bangalore remitted comparable selection issue to AO/TPO to examine whether company had operating profit in one of three preceding years. Working capital adjustment was allowed following OECD guidelines to maintain comparables for transfer pricing analysis. Risk adjustment issue was remitted to TPO/AO for factual determination with proper opportunity for assessee to substantiate claims. Recovery of pass-through costs was treated as operating income requiring mark-up, rejecting assessee's addendum as tax evasion device lacking genuineness. Interest on outstanding receivables adjustment was remitted to AO/TPO for determination following Bombay HC precedent limiting notional interest to LIBOR+2%. en-us Mon, 27 Mar 2023 00:00:00 +0530 Thu, 14 Dec 2023 20:04:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311256 ITAT Bangalore remitted comparable selection issue to AO/TPO to examine whether company had operating profit in one of three preceding years. Working capital adjustment was allowed following OECD guidelines to maintain comparables for transfer pricing analysis. Risk adjustment issue was remitted to TPO/AO for factual determination with proper opportunity for assessee to substantiate claims. Recovery of pass-through costs was treated as operating income requiring mark-up, rejecting assessee's addendum as tax evasion device lacking genuineness. Interest on outstanding receivables adjustment was remitted to AO/TPO for determination following Bombay HC precedent limiting notional interest to LIBOR+2%. Case-Laws Income Tax Mon, 27 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311256