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    <title>2025 (12) TMI 1864 - ITAT CHENNAI</title>
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    <description>Transfer pricing benchmarking under TNMM must use functionally similar comparables; diversified companies outside the assessee&#039;s automotive manufacturing profile were found unsuitable, and the matter was remitted for fresh benchmarking with automotive-sector comparables and appropriate economic adjustments. Notional interest on overdue receivables was held unwarranted where the assessee was debt free and bore no corresponding interest cost, so the TP adjustment was deleted. The appeal was thus partly allowed in favour of the assessee.</description>
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      <description>Transfer pricing benchmarking under TNMM must use functionally similar comparables; diversified companies outside the assessee&#039;s automotive manufacturing profile were found unsuitable, and the matter was remitted for fresh benchmarking with automotive-sector comparables and appropriate economic adjustments. Notional interest on overdue receivables was held unwarranted where the assessee was debt free and bore no corresponding interest cost, so the TP adjustment was deleted. The appeal was thus partly allowed in favour of the assessee.</description>
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