https://www.taxtmi.com/caselaws?id=770805 ITAT Mumbai ruled on multiple transfer pricing and tax issues for a captive service provider. The tribunal directed exclusion of two companies from comparable selection as they were functionally dissimilar high-risk entities compared to the low-risk assessee. No markup was required on pass-through expense reimbursements. Mark-to-market forex derivative losses were allowed as revenue deductions following SC precedent in Woodward Governor. The tribunal remanded several issues including Section 14A disallowance computation, bad debt verification per TRF Ltd ratio, business loss examination, and foreign tax credit claims for fresh verification. Year-end expense provisions were allowed based on business practice. MAT provisions under Section 115JB were held inapplicable to banking institutions per Bombay HC precedent. en-us Wed, 30 Apr 2025 00:00:00 +0530 Thu, 15 May 2025 11:47:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770805 ITAT Mumbai ruled on multiple transfer pricing and tax issues for a captive service provider. The tribunal directed exclusion of two companies from comparable selection as they were functionally dissimilar high-risk entities compared to the low-risk assessee. No markup was required on pass-through expense reimbursements. Mark-to-market forex derivative losses were allowed as revenue deductions following SC precedent in Woodward Governor. The tribunal remanded several issues including Section 14A disallowance computation, bad debt verification per TRF Ltd ratio, business loss examination, and foreign tax credit claims for fresh verification. Year-end expense provisions were allowed based on business practice. MAT provisions under Section 115JB were held inapplicable to banking institutions per Bombay HC precedent. Case-Laws Income Tax Wed, 30 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770805