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    <description>AMP expenditure was not sustained as an international transaction merely by applying the Bright Line Test; the matter was restored for fresh action in line with the final Supreme Court position. Transfer pricing adjustment for information technology support services was deleted because the assessee&#039;s actual function was limited IT help desk and support work, and comparables from a software development profile were functionally mismatched. Advances written off were treated as business losses arising in the ordinary course of business, so the disallowance was deleted. Brokerage for office lease was allowed in the year incurred because the expenditure crystallised on payment, notwithstanding the fixed lease term.</description>
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