https://www.taxtmi.com/caselaws?id=776846 ITAT JAIPUR - AT set aside transfer-pricing adjustments, holding the revenue erred in applying Berry ratio and rejecting the taxpayer's functionally similar comparables without proper Rule 10B/10C analysis; TNMM, if applied, required OP/OC as PLI and the reported margin was within arm's-length. Notional interest on intercompany receivables was deleted given uniform credit terms (up to 180 days) and industry practice. PF addition for delayed payment was deleted on facts. Section 115QA levy on buy-back was quashed as the proviso relied on by revenue was not in public domain when actions were taken. Unexplained expenses addition under s.69C was deleted. en-us Mon, 30 Jun 2025 00:00:00 +0530 Wed, 20 Aug 2025 08:34:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776846 ITAT JAIPUR - AT set aside transfer-pricing adjustments, holding the revenue erred in applying Berry ratio and rejecting the taxpayer's functionally similar comparables without proper Rule 10B/10C analysis; TNMM, if applied, required OP/OC as PLI and the reported margin was within arm's-length. Notional interest on intercompany receivables was deleted given uniform credit terms (up to 180 days) and industry practice. PF addition for delayed payment was deleted on facts. Section 115QA levy on buy-back was quashed as the proviso relied on by revenue was not in public domain when actions were taken. Unexplained expenses addition under s.69C was deleted. Case-Laws Income Tax Mon, 30 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776846