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    <description>Transfer pricing adjustments for intra-group management fee, SAP support fee, Microsoft licence fee, trademark royalty, engineering services and global IT services were deleted because the assessee had produced primary documentary evidence, and the tax authorities were required to examine that material rather than apply a nil arm&#039;s length price on broad assumptions. The adjustment relating to restricted stock units was also deleted because the arrangement was supported by agreement, cost workings and accounting entries, showing a business-linked recharge. The Form 26AS mismatch and the claim for deduction of education cess and higher and secondary education cess were remanded for fresh verification and adjudication.</description>
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