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    <title>2023 (8) TMI 1179 - ITAT DELHI</title>
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    <description>The appeal was partly allowed for statistical purposes. The Transfer Pricing Adjustments related to Export Commission and Model Fee were decided in favor of the assessee, directing deletion of adjustments. Corporate Tax Grounds issues regarding Signage Expenses, Sales Tools Expenses, and Capitalization of Royalty Expenses were also decided in favor of the assessee. Disallowances under sections 80G and 80JJAA were remitted for further verification. The claim of deduction for Technical Know-how expenses was allowed based on CBDT Circular No. 14(XL-35). The issue of Payment of Gratuity was remitted for factual verification, and the levy of Education Cess was upheld.</description>
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      <link>https://www.taxtmi.com/caselaws?id=442200</link>
      <description>The appeal was partly allowed for statistical purposes. The Transfer Pricing Adjustments related to Export Commission and Model Fee were decided in favor of the assessee, directing deletion of adjustments. Corporate Tax Grounds issues regarding Signage Expenses, Sales Tools Expenses, and Capitalization of Royalty Expenses were also decided in favor of the assessee. Disallowances under sections 80G and 80JJAA were remitted for further verification. The claim of deduction for Technical Know-how expenses was allowed based on CBDT Circular No. 14(XL-35). The issue of Payment of Gratuity was remitted for factual verification, and the levy of Education Cess was upheld.</description>
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