Landmark Tax Ruling Provides Critical Guidance on Transfer Pricing, Forex Losses, and Expense Deductibility for Businesses

ITAT ruled on multiple transfer pricing and tax-related issues. Key outcomes include: directing TPO to exclude certain comparables from transfer pricing analysis, allowing deduction of forex derivative mark-to-market losses, instructing AO to reexamine disallowances related to bad debts and business expenses, and confirming non-applicability of MAT provisions for banking institutions. The tribunal generally provided directives for reassessment, emphasizing compliance with legal precedents and granting opportunities for the assessee to substantiate claims. Most disputed items were remanded for fresh examination in accordance with established legal principles and Supreme Court interpretations. .....

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