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    <title>2026 (5) TMI 164 - ITAT BANGALORE</title>
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    <description>Delayed receivables from associated enterprises may be treated as a separate transfer pricing item only on a justified arm&#039;s-length basis, and an unsupported LIBOR plus 450 basis points benchmark was replaced with LIBOR plus 200 basis points. ESOP cost did not require substantive examination because the related transfer pricing adjustment had already fallen away, leaving that issue infructuous. Donations made to eligible charitable trusts did not lose deduction under section 80G merely because they formed part of CSR expenditure and had been disallowed in business income computation; the independent Chapter VI-A deduction remained available.</description>
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    <pubDate>Wed, 31 Dec 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=790962</link>
      <description>Delayed receivables from associated enterprises may be treated as a separate transfer pricing item only on a justified arm&#039;s-length basis, and an unsupported LIBOR plus 450 basis points benchmark was replaced with LIBOR plus 200 basis points. ESOP cost did not require substantive examination because the related transfer pricing adjustment had already fallen away, leaving that issue infructuous. Donations made to eligible charitable trusts did not lose deduction under section 80G merely because they formed part of CSR expenditure and had been disallowed in business income computation; the independent Chapter VI-A deduction remained available.</description>
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