https://www.taxtmi.com/caselaws?id=463157 ITAT Bangalore directed inclusion of Satyam Venture Engineering Service Pvt. Ltd. as a comparable for transfer pricing, allowing the assessee to rely solely on it for determining ALP. The TPO was instructed to recompute profit margins of Mahindra and Genesis comparables, complying with DRP directions, as per section 144C(10). Regarding interest on delayed receivables, the Tribunal held LIBOR+200 basis points acceptable instead of LIBOR+450, partially allowing the assessee's claim. On disallowance of payments to a non-resident auditor due to non-deduction of TDS under section 40(a)(i), the Tribunal noted that proceedings under section 143(1) merge with the assessment order and directed the AO to promptly dispose of the assessee's application under section 154 to avoid multiplicity of proceedings. en-us Wed, 15 Jan 2025 00:00:00 +0530 Thu, 07 Aug 2025 12:24:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463157 ITAT Bangalore directed inclusion of Satyam Venture Engineering Service Pvt. Ltd. as a comparable for transfer pricing, allowing the assessee to rely solely on it for determining ALP. The TPO was instructed to recompute profit margins of Mahindra and Genesis comparables, complying with DRP directions, as per section 144C(10). Regarding interest on delayed receivables, the Tribunal held LIBOR+200 basis points acceptable instead of LIBOR+450, partially allowing the assessee's claim. On disallowance of payments to a non-resident auditor due to non-deduction of TDS under section 40(a)(i), the Tribunal noted that proceedings under section 143(1) merge with the assessment order and directed the AO to promptly dispose of the assessee's application under section 154 to avoid multiplicity of proceedings. Case-Laws Income Tax Wed, 15 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463157