https://www.taxtmi.com/caselaws?id=777315 ITAT held that receipts from sale of packing-material scrap, though shown as "Other Income" in financials, arise from and are linked to the assessee's manufacturing operations and therefore must be treated as operating income for computing operating margin; CIT(A)'s reclassification was upheld. The Tribunal also held that FCCDs denominated in Indian currency resemble domestic term loans and should be benchmarked to domestic SBI PLR; applying the average SBI PLR (˜14.46% for the relevant year) the assessee's interest rate of 13.50% was found to be at arm's length and the direction to adopt SBI PLR as ALP was upheld. en-us Fri, 01 Aug 2025 00:00:00 +0530 Thu, 28 Aug 2025 08:32:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777315 ITAT held that receipts from sale of packing-material scrap, though shown as "Other Income" in financials, arise from and are linked to the assessee's manufacturing operations and therefore must be treated as operating income for computing operating margin; CIT(A)'s reclassification was upheld. The Tribunal also held that FCCDs denominated in Indian currency resemble domestic term loans and should be benchmarked to domestic SBI PLR; applying the average SBI PLR (˜14.46% for the relevant year) the assessee's interest rate of 13.50% was found to be at arm's length and the direction to adopt SBI PLR as ALP was upheld. Case-Laws Income Tax Fri, 01 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777315