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    <description>Transfer pricing comparability was refined by excluding Coral Hubs Ltd., Eclerx Services Ltd., Accentia Technologies Ltd. and Cosmic Global Ltd. as invalid comparables because they were functionally dissimilar, followed materially different outsourcing or service models, lacked reliable segmental data, or were affected by extraordinary events. The write off of fixed assets was treated as a non-normal, non-operating item rather than depreciation and was directed to be excluded from operating cost for margin computation, with consistency required where comparables had similar expenditure. The overall result was partial relief through adjustment of the comparable set and operating margin calculation.</description>
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