https://www.taxtmi.com/caselaws?id=449596 The ITAT Visakhapatnam held that Kitex Garments Limited, Kewal Kiran Clothing Ltd, and Virat Industries Ltd should be excluded as comparables for transfer pricing analysis due to functional differences from the assessee's garment processing business. The tribunal directed that liabilities written back be treated as operating income following Tetra Pak India Ltd precedent. Foreign exchange losses were deemed non-operating for mark-up purposes. The tribunal allowed statistical relief on working capital adjustments and extraordinary expenses, directing authorities to provide fresh opportunities for documentation. Separate adjustment for notional interest on receivables was rejected, holding that TNM method adequately captures such costs. en-us Tue, 13 Feb 2024 00:00:00 +0530 Wed, 14 Feb 2024 14:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449596 The ITAT Visakhapatnam held that Kitex Garments Limited, Kewal Kiran Clothing Ltd, and Virat Industries Ltd should be excluded as comparables for transfer pricing analysis due to functional differences from the assessee's garment processing business. The tribunal directed that liabilities written back be treated as operating income following Tetra Pak India Ltd precedent. Foreign exchange losses were deemed non-operating for mark-up purposes. The tribunal allowed statistical relief on working capital adjustments and extraordinary expenses, directing authorities to provide fresh opportunities for documentation. Separate adjustment for notional interest on receivables was rejected, holding that TNM method adequately captures such costs. Case-Laws Income Tax Tue, 13 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449596