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    <title>2025 (3) TMI 1081 - ITAT DELHI</title>
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    <description>ITAT DELHI allowed the assessee&#039;s appeal on three grounds. First, regarding additions of advance received from customers, the tribunal followed its earlier order and SC precedent in Taparia Tools Ltd., allowing deduction of entire expenditure when actually paid. Second, disallowance of security deposit written off was permitted as business loss given the small amount relative to assessee&#039;s income and its revenue nature for tender participation. Third, TP adjustments for commission received from Associated Enterprise were deleted after excluding dissimilar comparables, resulting in operating profit margin of 13.98%, and considering TPO&#039;s acceptance of commission as Arm&#039;s Length in subsequent years.</description>
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      <link>https://www.taxtmi.com/caselaws?id=767695</link>
      <description>ITAT DELHI allowed the assessee&#039;s appeal on three grounds. First, regarding additions of advance received from customers, the tribunal followed its earlier order and SC precedent in Taparia Tools Ltd., allowing deduction of entire expenditure when actually paid. Second, disallowance of security deposit written off was permitted as business loss given the small amount relative to assessee&#039;s income and its revenue nature for tender participation. Third, TP adjustments for commission received from Associated Enterprise were deleted after excluding dissimilar comparables, resulting in operating profit margin of 13.98%, and considering TPO&#039;s acceptance of commission as Arm&#039;s Length in subsequent years.</description>
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