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    <title>2022 (11) TMI 529 - ITAT MUMBAI</title>
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    <description>Under TNMM, third-party freight costs that are back-to-back pass-through expenses were treated as outside the assessee&#039;s own functional cost base, so the appropriate PLI was operating profit/value added expenses rather than operating profit/total cost. A transport company with substantial owned assets and a materially different functional profile was held not to be a valid comparable for a low-asset logistics service provider and was excluded from the comparables set. The short grant of TDS credit was treated as a verification matter, requiring examination of Form 26AS and entitlement before credit could be allowed.</description>
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