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    <title>2019 (7) TMI 1827 - ITAT PUNE</title>
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    <description>Segmental results supported by separate books and a Cost Accountant&#039;s certificate were accepted for transfer pricing, and an entity-level margin approach was rejected where no sustainable basis existed to discard the taxpayer&#039;s consistently followed method. Finance cost and interest charges were treated as non-operating expenses for profit level indicator computation. Bad debts written off were allowed, while the provision for operating expenses was disallowed; the resulting tax treatment had to be reflected in operating cost and operating income calculations. Export incentives were included in operating income. Transfer pricing adjustment was confined to international transactions and could not be applied to the entire segmental turnover.</description>
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