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    <title>2024 (4) TMI 451 - ITAT DELHI</title>
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    <description>Omission of clause (i) of section 92BA was treated as removing the statutory basis for the domestic transfer pricing reference, so the related adjustment could not survive, and prior reporting of the transaction did not preclude challenge. In valuing development rights, capitalisation in the accounts did not exclude transfer pricing scrutiny, but circle rate was held to be an unsuitable benchmark for arm&#039;s length valuation, and the assessee&#039;s valuation was preferred on the facts. Routine business expenditure required fresh factual verification. On interest paid on CCDs/OCDs, the broader comparable set and median-based analysis were accepted, and the adjustment was deleted.</description>
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