https://www.taxtmi.com/caselaws?id=463479 ITAT directed the AO/TPO to exclude comparables with turnover exceeding Rs. 200 crore from the benchmarking set after verification, and to remove specific comparables found functionally dissimilar; one comparable was remitted to the AO/TPO to reassess using Indian-branch data. Interest on intercompany loans was fixed at 5% p.a. (benchmarked) instead of 17.45%. additions under section 14A and explanation (f) to section 115JB(2) were deleted as no exempt income was earned. MAT computation and denial of long-term capital loss were remitted to the AO for fresh adjudication. Interest under section 234C is to be recalculated on return income. en-us Mon, 30 Sep 2024 00:00:00 +0530 Wed, 03 Sep 2025 19:06:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463479 ITAT directed the AO/TPO to exclude comparables with turnover exceeding Rs. 200 crore from the benchmarking set after verification, and to remove specific comparables found functionally dissimilar; one comparable was remitted to the AO/TPO to reassess using Indian-branch data. Interest on intercompany loans was fixed at 5% p.a. (benchmarked) instead of 17.45%. additions under section 14A and explanation (f) to section 115JB(2) were deleted as no exempt income was earned. MAT computation and denial of long-term capital loss were remitted to the AO for fresh adjudication. Interest under section 234C is to be recalculated on return income. Case-Laws Income Tax Mon, 30 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463479