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        Case ID :
        Income Tax

        Directives address transfer pricing comparables and an ECB...

        Transfer Pricing Comparable Selection: specified comparables ordered included, one excluded for functional dissimilarity and ECB interest deleted.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                Directives address transfer pricing comparables and an ECB interest adjustment: three comparables newly available are to be included in the TP study and one additional comparable (previously directed) must be included; one comparable is to be excluded as functionally dissimilar because it serves specialized defence R&D activities unlike the taxpayer's telecom operations; an interest addition on unsecured related-party external commercial borrowing is deleted by application of the consistency principle since identical borrowings and interest were accepted in earlier years. Outcomes: include specified comparables, exclude the functionally dissimilar comparable, and delete the ECB interest adjustment.
                                Note: It is a system-generated summary and is for quick reference only.
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                                  ActsIncome Tax
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