https://www.taxtmi.com/caselaws?id=466124 Transfer pricing adjustment disputes concern aggregation of international transactions, segmental accounting, tested party selection, comparable selection, valuation of corporate guarantees, notional interest on receivables, and carryforward of unabsorbed depreciation. Tribunal found the taxpayer provided allocation keys, segmental cost bifurcation and direct expense allocation, and directed AO/TPO to determine ALP by aggregating transactions with each associate enterprise separately and to exclude non-AE entity-level transactions; comparables must be selected on functional similarity using the most appropriate method. Tested party selection for raw material purchases is remitted for substantiation. Corporate guarantee valuation and notional interest issues are remitted for fresh adjudication using OECD guidance; AO to consider set-off of unabsorbed depreciation. en-us Fri, 14 Feb 2025 00:00:00 +0530 Sun, 25 Jan 2026 21:24:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466124 Transfer pricing adjustment disputes concern aggregation of international transactions, segmental accounting, tested party selection, comparable selection, valuation of corporate guarantees, notional interest on receivables, and carryforward of unabsorbed depreciation. Tribunal found the taxpayer provided allocation keys, segmental cost bifurcation and direct expense allocation, and directed AO/TPO to determine ALP by aggregating transactions with each associate enterprise separately and to exclude non-AE entity-level transactions; comparables must be selected on functional similarity using the most appropriate method. Tested party selection for raw material purchases is remitted for substantiation. Corporate guarantee valuation and notional interest issues are remitted for fresh adjudication using OECD guidance; AO to consider set-off of unabsorbed depreciation. Case-Laws Income Tax Fri, 14 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466124