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    <title>2025 (10) TMI 579 - ITAT DELHI</title>
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    <description>ITAT DELHI - AT held that basic market research and testing services constitute separate international transactions and were appropriately benchmarked by the TPO, but infrastructure services fees and reimbursements to the AE are distinct transactions requiring separate benchmarking and verification. The assessee&#039;s contention that accepted TP adjustments obviated further verification was rejected. Additional evidence submitted was accepted and remitted to the file of the AO/TPO with directions to verify and redo the TP study based on the record and law. The assessee&#039;s appeal is allowed for statistical purposes.</description>
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    <pubDate>Wed, 08 Oct 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=779783</link>
      <description>ITAT DELHI - AT held that basic market research and testing services constitute separate international transactions and were appropriately benchmarked by the TPO, but infrastructure services fees and reimbursements to the AE are distinct transactions requiring separate benchmarking and verification. The assessee&#039;s contention that accepted TP adjustments obviated further verification was rejected. Additional evidence submitted was accepted and remitted to the file of the AO/TPO with directions to verify and redo the TP study based on the record and law. The assessee&#039;s appeal is allowed for statistical purposes.</description>
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