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of TP adjustment upheld as per Special Bench ruling in Instrumentarium rejecting base erosion argument. Benefit of tax treaty against TP provisions rejected following earlier ITAT order. Mirror ALP principle rejected relying on Filtrex Technologies. Receipts taxable only on receipt basis per Ampacet Cyprus to be re-adjudicated. Software income treated as non-royalty and Global P&T services, HLPL receipts, L&T services income held as non-fees for technical services deleting respective additions following earlier ITAT orders.
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