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    <title>Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must track LIBOR.</title>
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    <description>Segmental financials for transfer pricing cannot be rejected at the threshold merely because they are not audited or show variance between AE and non-AE margins; the proper course is to test allocation keys, verify expense apportionment, and then independently decide acceptance for arm&#039;s length price determination. The Tribunal therefore restored the segmental benchmarking issue for fresh examination. On working capital adjustment, the TPO had to apply transfer pricing principles to the assessee&#039;s claim and could not reject it on broad grounds; if allowed, the receivables adjustment would fall away. If interest remains leviable on overdue foreign-currency invoices, it must be benchmarked with LIBOR-based rates, not SBI PLR. The matter was remanded for fresh determination.</description>
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    <pubDate>Sat, 11 Apr 2026 08:53:11 +0530</pubDate>
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      <title>Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must track LIBOR.</title>
      <link>https://www.taxtmi.com/highlights?id=98697</link>
      <description>Segmental financials for transfer pricing cannot be rejected at the threshold merely because they are not audited or show variance between AE and non-AE margins; the proper course is to test allocation keys, verify expense apportionment, and then independently decide acceptance for arm&#039;s length price determination. The Tribunal therefore restored the segmental benchmarking issue for fresh examination. On working capital adjustment, the TPO had to apply transfer pricing principles to the assessee&#039;s claim and could not reject it on broad grounds; if allowed, the receivables adjustment would fall away. If interest remains leviable on overdue foreign-currency invoices, it must be benchmarked with LIBOR-based rates, not SBI PLR. The matter was remanded for fresh determination.</description>
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