https://www.taxtmi.com/caselaws?id=777408 ITAT, Bangalore partly allowed the appeal: it rejected the TPO's notional interest adjustment because the receipts were advances settling intra-group receivables leaving no outstanding benefit; marketing costs and identified non-operational bank charges were excluded from the PLI; the assessee's artificial segmentation was disallowed as manipulative; several comparables wrongly excluded by the TPO were directed to be included after verification while certain others were held non-comparable; the matter was remitted to TPO/AO to recompute ALP/PLI accordingly. AO directed to apply corporate tax as per section 115BBA after verification. en-us Tue, 05 Aug 2025 00:00:00 +0530 Sat, 09 May 2026 11:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777408 ITAT, Bangalore partly allowed the appeal: it rejected the TPO's notional interest adjustment because the receipts were advances settling intra-group receivables leaving no outstanding benefit; marketing costs and identified non-operational bank charges were excluded from the PLI; the assessee's artificial segmentation was disallowed as manipulative; several comparables wrongly excluded by the TPO were directed to be included after verification while certain others were held non-comparable; the matter was remitted to TPO/AO to recompute ALP/PLI accordingly. AO directed to apply corporate tax as per section 115BBA after verification. Case-Laws Income Tax Tue, 05 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777408