https://www.taxtmi.com/caselaws?id=769342 ITAT Hyderabad ruled in favor of the assessee on multiple transfer pricing adjustments. The tribunal deleted TP adjustments on ECB interest payments at LIBOR+500 basis points, finding them at arm's length based on precedent. Royalty payment adjustments were also deleted, holding that TPO's benefit test determining ALP at nil was arbitrary when payments were made under RBI-approved agreements. Interest adjustments on trade receivables were deleted after applying netting principle, as payables exceeded receivables substantially. The tribunal remanded CPC processing issues to AO for verification of suo-moto disallowances and directed compliance with SC precedent on employee contribution delays. en-us Mon, 21 Apr 2025 00:00:00 +0530 Thu, 24 Apr 2025 09:13:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769342 ITAT Hyderabad ruled in favor of the assessee on multiple transfer pricing adjustments. The tribunal deleted TP adjustments on ECB interest payments at LIBOR+500 basis points, finding them at arm's length based on precedent. Royalty payment adjustments were also deleted, holding that TPO's benefit test determining ALP at nil was arbitrary when payments were made under RBI-approved agreements. Interest adjustments on trade receivables were deleted after applying netting principle, as payables exceeded receivables substantially. The tribunal remanded CPC processing issues to AO for verification of suo-moto disallowances and directed compliance with SC precedent on employee contribution delays. Case-Laws Income Tax Mon, 21 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769342