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    <title>2025 (7) TMI 1035 - ITAT DELHI</title>
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    <description>Transfer pricing benchmarking had to be redone where comparables were affected by high related party transactions, functional dissimilarity, and incorrect working capital margin computation, and the matter was remanded for fresh analysis with a related party transactions filter capped at 25%. Interest under sections 234B and 234C was not to be levied on additional income arising solely from a modified return filed pursuant to an advance pricing agreement, as that income could not have been anticipated for advance tax purposes. Credit of prepaid taxes was to be granted after verification. The appeal succeeded substantially on these grounds, while no relief was granted on the remaining penalty initiation challenge.</description>
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      <link>https://www.taxtmi.com/caselaws?id=774967</link>
      <description>Transfer pricing benchmarking had to be redone where comparables were affected by high related party transactions, functional dissimilarity, and incorrect working capital margin computation, and the matter was remanded for fresh analysis with a related party transactions filter capped at 25%. Interest under sections 234B and 234C was not to be levied on additional income arising solely from a modified return filed pursuant to an advance pricing agreement, as that income could not have been anticipated for advance tax purposes. Credit of prepaid taxes was to be granted after verification. The appeal succeeded substantially on these grounds, while no relief was granted on the remaining penalty initiation challenge.</description>
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