https://www.taxtmi.com/caselaws?id=780193 ITAT remitted the issue of selecting the foreign AE as the tested party to the file of the AO/TPO, directing the assessee to furnish requisite financial data and directing the TPO to test reliability of the selected tested party and determine ALP after hearing; similar separate exercise ordered for raw material/API transactions. The Tribunal upheld TPO/DRP that capitalized R&D treated as impairment was operating expense and dismissed that ground, but directed exclusion of loss on sale/disposal of PPE from operating expenses. One comparable was excluded for failing the export filter. Overdue receivables from AEs were held to be international transactions; TPO to compute notional interest at LIBOR plus applicable markup under Rule 10CB. en-us Wed, 24 Sep 2025 00:00:00 +0530 Sat, 25 Oct 2025 09:00:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780193 ITAT remitted the issue of selecting the foreign AE as the tested party to the file of the AO/TPO, directing the assessee to furnish requisite financial data and directing the TPO to test reliability of the selected tested party and determine ALP after hearing; similar separate exercise ordered for raw material/API transactions. The Tribunal upheld TPO/DRP that capitalized R&D treated as impairment was operating expense and dismissed that ground, but directed exclusion of loss on sale/disposal of PPE from operating expenses. One comparable was excluded for failing the export filter. Overdue receivables from AEs were held to be international transactions; TPO to compute notional interest at LIBOR plus applicable markup under Rule 10CB. Case-Laws Income Tax Wed, 24 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780193