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    <title>2016 (5) TMI 869 - ITAT DELHI</title>
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    <description>The Tribunal partly allowed the appeals for both assessment years, remitting several issues back to the AO/TPO for reconsideration. The adjustments related to AMP expenses were deleted, following a precedent set in an earlier case. The Tribunal set aside the transfer pricing adjustments on royalty payments for reconsideration. Additionally, the disallowance of royalty and technical guidance fees as capital expenditure was allowed. The disallowance of export commission and relocation expenses was also overturned. The provision for slow-moving inventory was deemed allowable, and the issue of credit for tax deducted at source was referred back for verification.</description>
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      <link>https://www.taxtmi.com/caselaws?id=327888</link>
      <description>The Tribunal partly allowed the appeals for both assessment years, remitting several issues back to the AO/TPO for reconsideration. The adjustments related to AMP expenses were deleted, following a precedent set in an earlier case. The Tribunal set aside the transfer pricing adjustments on royalty payments for reconsideration. Additionally, the disallowance of royalty and technical guidance fees as capital expenditure was allowed. The disallowance of export commission and relocation expenses was also overturned. The provision for slow-moving inventory was deemed allowable, and the issue of credit for tax deducted at source was referred back for verification.</description>
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