Transfer pricing: ITAT upholds distribution segment adjustment, treats AE overdue receivables as separate Section 92B international transaction

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....ITAT upheld the TPO's transfer pricing adjustment on the distribution segment by rejecting the assessee's plea for inclusion of additional comparables. The Tribunal held that the proposed entities did not figure in either the assessee's own accept-reject matrix or the TPO's search metrics, and their selective inclusion would amount to impermissible cherry-picking, undermining the integrity of the comparability analysis. On the TP adjustment for interest on overdue receivables from AEs, ITAT ruled that such receivables constitute an independent international transaction requiring separate benchmarking and cannot be netted off against outstanding payables to AEs, which do not generate income. The contention that a debt-free company need not charge interest was rejected, and the TP adjustment on interest was sustained against the assessee.....