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    <title>2020 (8) TMI 323 - ITAT DELHI</title>
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    <description>Transfer pricing comparables were aligned with the assessee&#039;s earlier-year position: Infosys BPO Ltd. and TCS E-Serve Ltd. were excluded because of comparability concerns, while R. Systems International Ltd., CG Vak Software Exports Ltd., Informed Technologies Ltd. and Caliber Point were treated as includible comparables. No separate adjustment for interest on receivables was considered necessary once working capital adjustment had already been granted. Deduction under section 10A was allowed for the AEGSC(STP) unit following consistent Tribunal views on similar facts. The disallowance relating to relocation expenses under section 40(a)(i) was restored for factual verification, and TDS credit was to be granted in accordance with law.</description>
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      <description>Transfer pricing comparables were aligned with the assessee&#039;s earlier-year position: Infosys BPO Ltd. and TCS E-Serve Ltd. were excluded because of comparability concerns, while R. Systems International Ltd., CG Vak Software Exports Ltd., Informed Technologies Ltd. and Caliber Point were treated as includible comparables. No separate adjustment for interest on receivables was considered necessary once working capital adjustment had already been granted. Deduction under section 10A was allowed for the AEGSC(STP) unit following consistent Tribunal views on similar facts. The disallowance relating to relocation expenses under section 40(a)(i) was restored for factual verification, and TDS credit was to be granted in accordance with law.</description>
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