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    <title>2026 (4) TMI 1374 - ITAT BANGALORE</title>
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    <description>Remeasurement gain on defined employee benefit plans was held operating in nature for TNMM because it had a direct nexus with employee-related business operations, so it had to be included in operating profit and cost. Comparable selection was guided by functional similarity and reliable segmental data: Fine Line Circuits Ltd. and HPL Electric &amp; Power Ltd. Cables segment were included, Sicame India Connectors Pvt. Ltd. was excluded on related party transaction grounds, and rejection of Autoneum Nittoku Soundproof Products India Pvt. Ltd. was upheld. Transfer pricing adjustment in the manufacturing segment was restricted to international transactions, not entire turnover. Notional interest on overdue receivables required separate benchmarking at LIBOR plus 200 basis points after the agreed credit period. Nil ALP for Concur expenses and corporate support charges was rejected, and tax credit claims were remitted for verification.</description>
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      <description>Remeasurement gain on defined employee benefit plans was held operating in nature for TNMM because it had a direct nexus with employee-related business operations, so it had to be included in operating profit and cost. Comparable selection was guided by functional similarity and reliable segmental data: Fine Line Circuits Ltd. and HPL Electric &amp; Power Ltd. Cables segment were included, Sicame India Connectors Pvt. Ltd. was excluded on related party transaction grounds, and rejection of Autoneum Nittoku Soundproof Products India Pvt. Ltd. was upheld. Transfer pricing adjustment in the manufacturing segment was restricted to international transactions, not entire turnover. Notional interest on overdue receivables required separate benchmarking at LIBOR plus 200 basis points after the agreed credit period. Nil ALP for Concur expenses and corporate support charges was rejected, and tax credit claims were remitted for verification.</description>
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