https://www.taxtmi.com/highlights?id=96089 The principal issue was whether AMP expenditure forms part of operating costs for ALP determination in related-party transactions; holding that the TP study wrongly excluded AMP from operating cost, the tribunal remands the ALP determination to AO/TPO directing AMP be treated within operating cost and re-evaluated accordingly. On interest for delayed receivables the tribunal holds such interest is a separate international transaction requiring separate benchmarking; credit period limited to 30 days per contract and the benchmark rate directed as LIBOR + 200 bps (replacing LIBOR + 400 bps). Seminar/convention expenses must be verified against the Supreme Court test and, if compliant, allowed. Alleged double disallowance under s.43B is remitted to AO to delete if already disallowed in computation. - ITAT en-us Fri, 16 Jan 2026 18:27:46 +0530 Fri, 16 Jan 2026 18:27:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96089 The principal issue was whether AMP expenditure forms part of operating costs for ALP determination in related-party transactions; holding that the TP study wrongly excluded AMP from operating cost, the tribunal remands the ALP determination to AO/TPO directing AMP be treated within operating cost and re-evaluated accordingly. On interest for delayed receivables the tribunal holds such interest is a separate international transaction requiring separate benchmarking; credit period limited to 30 days per contract and the benchmark rate directed as LIBOR + 200 bps (replacing LIBOR + 400 bps). Seminar/convention expenses must be verified against the Supreme Court test and, if compliant, allowed. Alleged double disallowance under s.43B is remitted to AO to delete if already disallowed in computation. - ITAT Highlights Income Tax Fri, 16 Jan 2026 18:27:46 +0530 https://www.taxtmi.com/highlights?id=96089