https://www.taxtmi.com/caselaws?id=463132 ITAT Bangalore held that the TPO erred in not computing the profit level indicator (PLI) of the comparable company as per its annual accounts, specifically by excluding bad debts written off as operating expenses. The dispute resolution panel's direction to compute margins based on annual accounts is binding under section 144C(10). The AO/TPO was directed to include bad debt expenses as operating expenditure when calculating the PLI for the comparable company and to retain any transfer pricing adjustment only to the extent justified by the arm's-length price of the international transaction. en-us Mon, 30 Dec 2024 00:00:00 +0530 Thu, 07 Aug 2025 20:34:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463132 ITAT Bangalore held that the TPO erred in not computing the profit level indicator (PLI) of the comparable company as per its annual accounts, specifically by excluding bad debts written off as operating expenses. The dispute resolution panel's direction to compute margins based on annual accounts is binding under section 144C(10). The AO/TPO was directed to include bad debt expenses as operating expenditure when calculating the PLI for the comparable company and to retain any transfer pricing adjustment only to the extent justified by the arm's-length price of the international transaction. Case-Laws Income Tax Mon, 30 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463132