https://www.taxtmi.com/highlights?id=87704 ITAT adjudicated multiple transfer pricing (TP) issues involving associated enterprises (AEs) transactions. The Tribunal comprehensively deleted TP adjustments related to external commercial borrowing (ECB) interest, royalty payments, and trade receivables/payables. Key holdings include: (1) ECB interest at LIBOR+500 basis is arm's length, (2) royalty payment determination at Nil is arbitrary, and (3) netting off notional interest considering both receivables and payables is appropriate. The Tribunal set aside CPC's mechanical adjustments, directing the Assessing Officer to verify suo-moto disallowances and employee contribution issues in accordance with established legal principles and recent judicial precedents. en-us Thu, 24 Apr 2025 09:13:28 +0530 Thu, 24 Apr 2025 09:13:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=87704 ITAT adjudicated multiple transfer pricing (TP) issues involving associated enterprises (AEs) transactions. The Tribunal comprehensively deleted TP adjustments related to external commercial borrowing (ECB) interest, royalty payments, and trade receivables/payables. Key holdings include: (1) ECB interest at LIBOR+500 basis is arm's length, (2) royalty payment determination at Nil is arbitrary, and (3) netting off notional interest considering both receivables and payables is appropriate. The Tribunal set aside CPC's mechanical adjustments, directing the Assessing Officer to verify suo-moto disallowances and employee contribution issues in accordance with established legal principles and recent judicial precedents. Highlights Income Tax Thu, 24 Apr 2025 09:13:28 +0530 https://www.taxtmi.com/highlights?id=87704