https://www.taxtmi.com/caselaws?id=781782 ITAT upheld the TPO's rejection of additional comparables proposed by the assessee in the distribution segment, holding that inclusion of companies not appearing in either the assessee's TP study accept-reject matrix or the TPO's search metrics would amount to impermissible cherry-picking and undermine comparability analysis. On the TP adjustment for interest on overdue receivables from AE, ITAT rejected the assessee's plea for netting such receivables against outstanding payables, holding that, in light of the retrospective amendment, delayed receivables constitute a separate international transaction requiring independent benchmarking. The tribunal also held that the assessee being debt-free is no ground to avoid charging arm's length interest. en-us Mon, 17 Nov 2025 00:00:00 +0530 Sat, 09 May 2026 11:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781782 ITAT upheld the TPO's rejection of additional comparables proposed by the assessee in the distribution segment, holding that inclusion of companies not appearing in either the assessee's TP study accept-reject matrix or the TPO's search metrics would amount to impermissible cherry-picking and undermine comparability analysis. On the TP adjustment for interest on overdue receivables from AE, ITAT rejected the assessee's plea for netting such receivables against outstanding payables, holding that, in light of the retrospective amendment, delayed receivables constitute a separate international transaction requiring independent benchmarking. The tribunal also held that the assessee being debt-free is no ground to avoid charging arm's length interest. Case-Laws Income Tax Mon, 17 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781782