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    <title>2026 (6) TMI 1166 - ITAT BANGALORE</title>
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    <description>Substantial turnover disparity was treated as a valid comparability factor in transfer pricing, because scale, economies of scale, market position, asset base and risk profile can materially affect profitability; companies with vastly higher turnover than the tested party were excluded where the operations were not broadly comparable. Delayed trade receivables from associated enterprises were treated as an international transaction, with benchmarking required after netting off receivables and payables relating to the same AE where appropriate. For foreign-currency receivables, the adjustment was recomputed using LIBOR plus a reasonable spread, reduced here to LIBOR plus 200 basis points. The result was partial relief through exclusion of selected comparables and recomputation of the receivables adjustment.</description>
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