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    <title>2025 (11) TMI 1900 - ITAT BANGALORE</title>
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    <description>ITAT Bangalore allowed the assessee&#039;s plea for applying an upper turnover filter in all segments and directed the TPO to exclude high-turnover comparables and recompute the arm&#039;s-length margin using the remaining set. The assessee&#039;s claim for inclusion of additional comparables not arising from the TPO&#039;s original search matrix was rejected as cherry-picking, including for the ITeS and market support segments. A comparable following a different financial year was directed to be included if the assessee can satisfactorily reconstruct matching-year financials. The issue of a disputed comparable failing the RPT filter was remanded to the TPO for uniform application of the filter. The TPO was directed to grant working capital adjustment where warranted, and to compute interest on overdue receivables only if such adjustment is denied, using the invoice currency.</description>
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    <pubDate>Tue, 11 Nov 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=782432</link>
      <description>ITAT Bangalore allowed the assessee&#039;s plea for applying an upper turnover filter in all segments and directed the TPO to exclude high-turnover comparables and recompute the arm&#039;s-length margin using the remaining set. The assessee&#039;s claim for inclusion of additional comparables not arising from the TPO&#039;s original search matrix was rejected as cherry-picking, including for the ITeS and market support segments. A comparable following a different financial year was directed to be included if the assessee can satisfactorily reconstruct matching-year financials. The issue of a disputed comparable failing the RPT filter was remanded to the TPO for uniform application of the filter. The TPO was directed to grant working capital adjustment where warranted, and to compute interest on overdue receivables only if such adjustment is denied, using the invoice currency.</description>
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      <pubDate>Tue, 11 Nov 2025 00:00:00 +0530</pubDate>
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