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    <title>2015 (4) TMI 911 - ITAT MUMBAI</title>
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    <description>For transfer pricing analysis, companies affected by extraordinary events such as acquisition, amalgamation or demerger during the relevant year are not reliable uncontrolled comparables because those events materially alter their functional profile. Eclerx Services Ltd. and Mold-Tek Technologies Ltd. were therefore excluded from the final comparable set, reducing the transfer pricing adjustment in the assessee&#039;s favour. The short-credit of TDS was not finally decided and was restored for verification at the assessment stage. The levy of interest under sections 234B and 234C was treated as mandatory and consequential, so no substantive relief was granted on that ground.</description>
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      <title>2015 (4) TMI 911 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=259030</link>
      <description>For transfer pricing analysis, companies affected by extraordinary events such as acquisition, amalgamation or demerger during the relevant year are not reliable uncontrolled comparables because those events materially alter their functional profile. Eclerx Services Ltd. and Mold-Tek Technologies Ltd. were therefore excluded from the final comparable set, reducing the transfer pricing adjustment in the assessee&#039;s favour. The short-credit of TDS was not finally decided and was restored for verification at the assessment stage. The levy of interest under sections 234B and 234C was treated as mandatory and consequential, so no substantive relief was granted on that ground.</description>
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