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    <description>Maintainability of the appeal was tested against the low-tax-effect policy under Clause 4 of the Circular dated 11 July 2018. As the tax effect was below the prescribed limit of 2 crores, the matter fell within the Union&#039;s policy and was disposed of on that ground. The document also notes transfer-pricing issues concerning the headcount method for allocating common expenses, consistency in applying the allocation method, comparability of associated and independent enterprises, and reliance on company website and internet material for selecting comparables, with remand for fresh consideration of comparables mentioned in the text.</description>
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