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    <title>2019 (1) TMI 1274 - BOMBAY HIGH COURT</title>
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    <description>Transaction charges paid to stock exchanges were not disallowable for want of tax deduction under section 194J, as the point stood concluded by binding Supreme Court precedent. In transfer pricing, interest earned on margin money placed by associated enterprises could be included in arm&#039;s length computation, but the comparison had to be based on interest earned on margin money from both associated and unrelated parties rather than turnover. A company that had undergone amalgamation during the relevant year could be excluded from comparables because the merger was an extraordinary event affecting profitability. A securities broker was not functionally comparable to merchant banking services where the Revenue failed to show similarity in activities.</description>
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      <description>Transaction charges paid to stock exchanges were not disallowable for want of tax deduction under section 194J, as the point stood concluded by binding Supreme Court precedent. In transfer pricing, interest earned on margin money placed by associated enterprises could be included in arm&#039;s length computation, but the comparison had to be based on interest earned on margin money from both associated and unrelated parties rather than turnover. A company that had undergone amalgamation during the relevant year could be excluded from comparables because the merger was an extraordinary event affecting profitability. A securities broker was not functionally comparable to merchant banking services where the Revenue failed to show similarity in activities.</description>
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