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    <title>2025 (10) TMI 702 - ITAT PUNE</title>
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    <description>ITAT PUNE - AT dismissed the Revenue&#039;s appeal, upholding the CIT(A)&#039;s deletions. The Tribunal accepted the assessee&#039;s selection of TNMM as the most appropriate MAM for benchmarking export transactions, following prior orders. Additions under section 40(a)(ia) for TDS failures were deleted based on reconciliations and subsequent reversals; ICDS-related adjustments were held properly disclosed and taxed; and deletions of disallowances for liquidated damages, project provisions and doubtful debts were sustained due to consistent prior treatment and absence of contrary material from Revenue.</description>
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      <link>https://www.taxtmi.com/caselaws?id=779906</link>
      <description>ITAT PUNE - AT dismissed the Revenue&#039;s appeal, upholding the CIT(A)&#039;s deletions. The Tribunal accepted the assessee&#039;s selection of TNMM as the most appropriate MAM for benchmarking export transactions, following prior orders. Additions under section 40(a)(ia) for TDS failures were deleted based on reconciliations and subsequent reversals; ICDS-related adjustments were held properly disclosed and taxed; and deletions of disallowances for liquidated damages, project provisions and doubtful debts were sustained due to consistent prior treatment and absence of contrary material from Revenue.</description>
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