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    <title>Payments to third-party clinical labs treated as pass-through, excluded from cost base; 13.71% margin upheld, s.143(3) jurisdiction denied</title>
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    <description>The ITAT upheld that payments to third-party clinical laboratories are pass-through costs and must be excluded from the assessee&#039;s cost base when computing operating margin for CSMM services; the assessee&#039;s adjusted margin was accepted at 13.71% (versus 10.34% prior). The Tribunal rejected benchmarking by reference to contract R&amp;D companies and sustained deletion of additions based on improper comparables, and affirmed that marketing support services should not be compared with high-end contract R&amp;D providers. Grounds of appeal by the Revenue were dismissed. The assessee&#039;s objection to the AO&#039;s exercise of jurisdiction under s.143(3) after 14 years was rejected.</description>
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    <pubDate>Tue, 19 Aug 2025 18:34:07 +0530</pubDate>
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      <title>Payments to third-party clinical labs treated as pass-through, excluded from cost base; 13.71% margin upheld, s.143(3) jurisdiction denied</title>
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      <description>The ITAT upheld that payments to third-party clinical laboratories are pass-through costs and must be excluded from the assessee&#039;s cost base when computing operating margin for CSMM services; the assessee&#039;s adjusted margin was accepted at 13.71% (versus 10.34% prior). The Tribunal rejected benchmarking by reference to contract R&amp;D companies and sustained deletion of additions based on improper comparables, and affirmed that marketing support services should not be compared with high-end contract R&amp;D providers. Grounds of appeal by the Revenue were dismissed. The assessee&#039;s objection to the AO&#039;s exercise of jurisdiction under s.143(3) after 14 years was rejected.</description>
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      <pubDate>Tue, 19 Aug 2025 18:34:07 +0530</pubDate>
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