https://www.taxtmi.com/caselaws?id=772279 ITAT Delhi upheld CIT(A)'s deletion of AMP expenditure additions, ruling it does not constitute an international transaction. The tribunal excluded Syngene International Limited as comparable due to unavailable segmental information but included Sequent Research Limited as valid comparable. Transfer pricing adjustments on interest receivables were deleted as revenue failed to controvert CIT(A)'s findings. For ECB interest transactions, the matter was remanded to AO for obtaining credit rating of associated enterprises, agreeing LIBOR is proper benchmarking. Raw material purchase adjustments were deleted as assessee demonstrated healthy gross margins at arm's length price. en-us Thu, 29 May 2025 00:00:00 +0530 Fri, 06 Jun 2025 08:30:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772279 ITAT Delhi upheld CIT(A)'s deletion of AMP expenditure additions, ruling it does not constitute an international transaction. The tribunal excluded Syngene International Limited as comparable due to unavailable segmental information but included Sequent Research Limited as valid comparable. Transfer pricing adjustments on interest receivables were deleted as revenue failed to controvert CIT(A)'s findings. For ECB interest transactions, the matter was remanded to AO for obtaining credit rating of associated enterprises, agreeing LIBOR is proper benchmarking. Raw material purchase adjustments were deleted as assessee demonstrated healthy gross margins at arm's length price. Case-Laws Income Tax Thu, 29 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772279