https://www.taxtmi.com/caselaws?id=765780 ITAT Bangalore allowed partial relief to the assessee in a transfer pricing dispute. The tribunal restored matters to TPO regarding trading segment arm's-length pricing, directing the assessee to substantiate foreign AE as tested party with reliable data. For intragroup services, the case was remanded to TPO with directions to examine service necessity, rendition, and commercial benefit. The tribunal dismissed grounds on delayed receivables interest, treating it as separate international transaction requiring benchmarking. Store closure expenses disallowance was deleted as expenditure was wholly for business purposes. Set-off of brought forward losses and unabsorbed depreciation was allowed per law. en-us Thu, 26 Dec 2024 00:00:00 +0530 Mon, 10 Feb 2025 07:50:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765780 ITAT Bangalore allowed partial relief to the assessee in a transfer pricing dispute. The tribunal restored matters to TPO regarding trading segment arm's-length pricing, directing the assessee to substantiate foreign AE as tested party with reliable data. For intragroup services, the case was remanded to TPO with directions to examine service necessity, rendition, and commercial benefit. The tribunal dismissed grounds on delayed receivables interest, treating it as separate international transaction requiring benchmarking. Store closure expenses disallowance was deleted as expenditure was wholly for business purposes. Set-off of brought forward losses and unabsorbed depreciation was allowed per law. Case-Laws Income Tax Thu, 26 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765780