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    <title>2026 (6) TMI 1070 - ITAT CHENNAI</title>
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    <description>In transfer pricing comparability analysis for the freight forwarding segment, working capital differences that materially affect margins had to be adjusted, and the authorities erred in denying the adjustment; the working capital adjustment was therefore allowed. AP Logistics and Dimension Logistics could not be excluded merely because related party transactions were not expressly disclosed, and both were directed to be included as comparables. Corporate overhead charges paid to the overseas associated enterprise could not be fixed at nil without proper benchmarking, so that issue was remanded for fresh verification. Separate notional interest on trade receivables was unsustainable where the assessee was debt free and no interest expenditure was shown; the adjustment was deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=793689</link>
      <description>In transfer pricing comparability analysis for the freight forwarding segment, working capital differences that materially affect margins had to be adjusted, and the authorities erred in denying the adjustment; the working capital adjustment was therefore allowed. AP Logistics and Dimension Logistics could not be excluded merely because related party transactions were not expressly disclosed, and both were directed to be included as comparables. Corporate overhead charges paid to the overseas associated enterprise could not be fixed at nil without proper benchmarking, so that issue was remanded for fresh verification. Separate notional interest on trade receivables was unsustainable where the assessee was debt free and no interest expenditure was shown; the adjustment was deleted.</description>
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