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    <title>2019 (5) TMI 1264 - ITAT BANGALORE</title>
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    <description>A stock-difference credit netted against raw material consumption for transfer pricing PLI computation was held not to justify an adjustment because it did not alter net profit, and the AO was directed to recompute the margin accordingly. The claims for inclusion of two comparables and for capacity-utilisation adjustment were rejected for want of functional comparability and adequate factual support, while the cash-profit PLI issue was remanded for verification. The computation of comparables&#039; net profit margins, and the section 10B deduction and consequential set-off of brought forward losses and unabsorbed depreciation, were also restored for fresh examination at assessment stage.</description>
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      <title>2019 (5) TMI 1264 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=380536</link>
      <description>A stock-difference credit netted against raw material consumption for transfer pricing PLI computation was held not to justify an adjustment because it did not alter net profit, and the AO was directed to recompute the margin accordingly. The claims for inclusion of two comparables and for capacity-utilisation adjustment were rejected for want of functional comparability and adequate factual support, while the cash-profit PLI issue was remanded for verification. The computation of comparables&#039; net profit margins, and the section 10B deduction and consequential set-off of brought forward losses and unabsorbed depreciation, were also restored for fresh examination at assessment stage.</description>
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