https://www.taxtmi.com/caselaws?id=780207 ITAT set aside the TPO's rejection of the taxpayer's certified segmental financials and held the TPO acted illegally in arbitrarily reallocating costs by operating revenue. Interest income and expense are non-operating for the hub activity and must be excluded from operating profit. Transfer pricing adjustment, if any, is limited to the international transaction (COGS) and not entire cost base. Recharacterisation of reimbursements and the adhoc 5% mark-up were disallowed. Disallowance of advertising expenditure was overturned. Appeals were allowed in favour of the assessee and TPO's adjustments were cancelled or restricted accordingly. en-us Fri, 10 Oct 2025 00:00:00 +0530 Sat, 25 Oct 2025 09:00:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780207 ITAT set aside the TPO's rejection of the taxpayer's certified segmental financials and held the TPO acted illegally in arbitrarily reallocating costs by operating revenue. Interest income and expense are non-operating for the hub activity and must be excluded from operating profit. Transfer pricing adjustment, if any, is limited to the international transaction (COGS) and not entire cost base. Recharacterisation of reimbursements and the adhoc 5% mark-up were disallowed. Disallowance of advertising expenditure was overturned. Appeals were allowed in favour of the assessee and TPO's adjustments were cancelled or restricted accordingly. Case-Laws Income Tax Fri, 10 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780207