https://www.taxtmi.com/caselaws?id=770557 ITAT-Bang held that the TPO's NIL benchmarking of royalty was unsustainable and directed adoption of TNMM to determine ALP, partly allowing the assessee's appeal for statistical purposes. Interest on outstanding receivables is an international transaction requiring separate benchmarking; PLR is inapplicable and LIBOR+200 bps with applicable credit period was accepted. Disallowance of gratuity under s.43B was deleted as payment was proved before the return due date and natural justice breached. Claims for foreign tax credit (Form 67) and DDT credit were restored for verification, and an ad-hoc interest levy was set aside pending AO's justification or deletion. en-us Fri, 09 May 2025 00:00:00 +0530 Tue, 14 Oct 2025 11:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770557 ITAT-Bang held that the TPO's NIL benchmarking of royalty was unsustainable and directed adoption of TNMM to determine ALP, partly allowing the assessee's appeal for statistical purposes. Interest on outstanding receivables is an international transaction requiring separate benchmarking; PLR is inapplicable and LIBOR+200 bps with applicable credit period was accepted. Disallowance of gratuity under s.43B was deleted as payment was proved before the return due date and natural justice breached. Claims for foreign tax credit (Form 67) and DDT credit were restored for verification, and an ad-hoc interest levy was set aside pending AO's justification or deletion. Case-Laws Income Tax Fri, 09 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770557