https://www.taxtmi.com/caselaws?id=779288 ITAT remanded the transfer pricing issue to the AO/TPO for fresh benchmarking of international transactions, accepting that key submissions were made for the first time on appeal and directing reconsideration; grounds 2-8 were partly allowed for statistical purposes. The tribunal directed that interest disallowed under proviso to section 36(1) be allowed as revenue expenditure. Expenditure treated as capital (advertising) was held to be revenue in nature and allowed, as it did not create a lasting capital asset or enduring advantage. en-us Mon, 08 Sep 2025 00:00:00 +0530 Sat, 04 Oct 2025 09:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779288 ITAT remanded the transfer pricing issue to the AO/TPO for fresh benchmarking of international transactions, accepting that key submissions were made for the first time on appeal and directing reconsideration; grounds 2-8 were partly allowed for statistical purposes. The tribunal directed that interest disallowed under proviso to section 36(1) be allowed as revenue expenditure. Expenditure treated as capital (advertising) was held to be revenue in nature and allowed, as it did not create a lasting capital asset or enduring advantage. Case-Laws Income Tax Mon, 08 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779288