https://www.taxtmi.com/caselaws?id=783879 The dominant issue was whether the DRP's directions on TP adjustment were vitiated for failure to adjudicate all objections on computation of operating margins of final comparables (including treasury expenses and interest on working capital loans). Applying s.144C(5) and (8), the ITAT held the DRP, as a quasi-judicial authority, must issue reasoned directions on every objection; omission rendered the directions non-speaking and contrary to natural justice, requiring factual verification from audited accounts. The TP issue was set aside to the DRP for fresh verification and recomputation. On foreign exchange loss and related charges, the disallowance was upheld, but the AO was directed to verify the correct quantum. On s.40(a)(ia), the AO was directed to verify the claim of lower TDS based on certificate and decide accordingly. en-us Fri, 14 Nov 2025 00:00:00 +0530 Wed, 24 Dec 2025 07:51:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783879 The dominant issue was whether the DRP's directions on TP adjustment were vitiated for failure to adjudicate all objections on computation of operating margins of final comparables (including treasury expenses and interest on working capital loans). Applying s.144C(5) and (8), the ITAT held the DRP, as a quasi-judicial authority, must issue reasoned directions on every objection; omission rendered the directions non-speaking and contrary to natural justice, requiring factual verification from audited accounts. The TP issue was set aside to the DRP for fresh verification and recomputation. On foreign exchange loss and related charges, the disallowance was upheld, but the AO was directed to verify the correct quantum. On s.40(a)(ia), the AO was directed to verify the claim of lower TDS based on certificate and decide accordingly. Case-Laws Income Tax Fri, 14 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783879