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    <description>SSI status for deduction under section 80IB was denied because the assessee failed to prove exclusion of claimed items from plant and machinery; the investment shown in the accounts, including computers and specialised software used in manufacturing, was treated as part of the relevant threshold base. Royalty paid to an associated enterprise could not be benchmarked at nil by reference to another group entity&#039;s non-charging of royalty, so the transfer pricing adjustment was deleted. The purchase adjustment from the associated enterprise was remitted for fresh computation because the underlying figures did not reconcile with the profit and loss account. Foreign exchange loss on loans for capital work was treated as capital in nature, with relief confined to depreciation.</description>
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