https://www.taxtmi.com/caselaws?id=776027 ITAT Delhi directed the TPO to include several functionally similar comparables accepted in prior AYs in the final set for transfer pricing adjustment, while excluding others due to non-comparability factors such as government grants or predominant R&D activities. The TPO was instructed to determine the arm's length price incorporating these comparables and to consider foreign exchange gains, duty drawback, and obsolete item compensation as operating revenue per settled law. The TPO's figure for international transactions was corrected, and payments for technical assistance from the AE were allowed based on evidence and proportionality to turnover. Interest on delayed receivables was to be computed at LIBOR plus 200 basis points with a 60-day credit period, allowing credit for amounts received within that period. The matter was remanded to the AO for compliance with these directions. en-us Thu, 31 Jul 2025 00:00:00 +0530 Mon, 04 Aug 2025 08:28:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776027 ITAT Delhi directed the TPO to include several functionally similar comparables accepted in prior AYs in the final set for transfer pricing adjustment, while excluding others due to non-comparability factors such as government grants or predominant R&D activities. The TPO was instructed to determine the arm's length price incorporating these comparables and to consider foreign exchange gains, duty drawback, and obsolete item compensation as operating revenue per settled law. The TPO's figure for international transactions was corrected, and payments for technical assistance from the AE were allowed based on evidence and proportionality to turnover. Interest on delayed receivables was to be computed at LIBOR plus 200 basis points with a 60-day credit period, allowing credit for amounts received within that period. The matter was remanded to the AO for compliance with these directions. Case-Laws Income Tax Thu, 31 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776027