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MEIS scrip income and duty drawback were treated as operating revenue for transfer pricing because they arose directly from the assessee's export and manufacturing activities; excluding them would distort operating profit, and the absence of similar incentives in comparables was not decisive. The Tribunal also directed examination of the working capital computation on record and grant of an appropriate adjustment while determining arm's length price. On CSR-linked donations, deduction under section 80G was allowed because CSR disallowance as business expenditure does not automatically bar section 80G relief, and the statutory exclusions were not shown to apply.
MEIS scrip income and duty drawback were treated as operating revenue for transfer pricing because they arose directly from the assessee's export and manufacturing activities; excluding them would distort operating profit, and the absence of similar incentives in comparables was not decisive. The Tribunal also directed examination of the working capital computation on record and grant of an appropriate adjustment while determining arm's length price. On CSR-linked donations, deduction under section 80G was allowed because CSR disallowance as business expenditure does not automatically bar section 80G relief, and the statutory exclusions were not shown to apply.
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