https://www.taxtmi.com/caselaws?id=767254 ITAT Bangalore ruled on multiple transfer pricing and tax issues. The tribunal held that notional costs for free services from associated enterprises should not be included in operating costs for calculating profit level indicators, directing TPO to exclude such costs. The comparable selection issue was remanded to TPO for fresh adjudication. Regarding outstanding receivables from associated enterprises, ITAT confirmed these constitute international transactions requiring separate benchmarking at LIBOR+200 basis points with 30-day credit period. Interest expenses on compulsorily convertible debentures were allowed as deduction. However, delayed provident fund contributions were disallowed following SC precedent in Checkmate Services. The tribunal directed verification and allowance of TDS credits per statutory provisions. en-us Wed, 18 Dec 2024 00:00:00 +0530 Thu, 13 Mar 2025 08:35:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767254 ITAT Bangalore ruled on multiple transfer pricing and tax issues. The tribunal held that notional costs for free services from associated enterprises should not be included in operating costs for calculating profit level indicators, directing TPO to exclude such costs. The comparable selection issue was remanded to TPO for fresh adjudication. Regarding outstanding receivables from associated enterprises, ITAT confirmed these constitute international transactions requiring separate benchmarking at LIBOR+200 basis points with 30-day credit period. Interest expenses on compulsorily convertible debentures were allowed as deduction. However, delayed provident fund contributions were disallowed following SC precedent in Checkmate Services. The tribunal directed verification and allowance of TDS credits per statutory provisions. Case-Laws Income Tax Wed, 18 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767254