https://www.taxtmi.com/caselaws?id=776100 ITAT Chennai remanded the marketing service fee issue to the TPO to accept the assessee's TNMM approach using foreign AEs as comparables after verifying additional evidence. The upward interest adjustment on trade receivables was deleted as the assessee did not charge interest on delayed payments from both AEs and non-AEs. The corporate guarantee fee adjustment was restricted to 0.5% of the utilized amount (AED 3.1 million), not the sanctioned limit, as no cost was incurred. Depreciation on ATM machines was allowed at 40% instead of 15%. The gratuity deduction disallowance was reversed since it pertained to reversal of excess provision. Bad debts written off were allowed as irrecoverable per settled law. Additional loss claims and ATM site rent deductions were remitted to the AO for verification and decision in accordance with law. en-us Tue, 03 Jun 2025 00:00:00 +0530 Tue, 05 Aug 2025 07:54:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776100 ITAT Chennai remanded the marketing service fee issue to the TPO to accept the assessee's TNMM approach using foreign AEs as comparables after verifying additional evidence. The upward interest adjustment on trade receivables was deleted as the assessee did not charge interest on delayed payments from both AEs and non-AEs. The corporate guarantee fee adjustment was restricted to 0.5% of the utilized amount (AED 3.1 million), not the sanctioned limit, as no cost was incurred. Depreciation on ATM machines was allowed at 40% instead of 15%. The gratuity deduction disallowance was reversed since it pertained to reversal of excess provision. Bad debts written off were allowed as irrecoverable per settled law. Additional loss claims and ATM site rent deductions were remitted to the AO for verification and decision in accordance with law. Case-Laws Income Tax Tue, 03 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776100