Transfer Pricing Adjustments: AE Trading, Intragroup Services, Interest on Receivables Under Review for Arm's Length Compliance

ITAT addressed multiple transfer pricing issues in an international business case. TPO was directed to reassess arm's-length pricing for trading segment transactions, allowing foreign AE as tested party if reliably substantiated. For intragroup services valued at nil, matter returned to TPO to evaluate service necessity, rendition, and economic benefit, excluding shareholder or duplicative services. Interest adjustment on delayed receivables upheld as separate international transaction, rejecting COVID-19 extension application. Store closure expenses disallowance reversed as expenditures were proven business-related. Set-off of brought forward business losses and unabsorbed depreciation allowed subject to legal compliance. TPO must provide fair hearing opportunity while determining revised arm's-length pricing. .....

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