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    <title>Transfer pricing on management services, software reimbursements and captive power rates; s.80-IA/MAT assessment errors corrected, adjustments deleted</title>
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    <description>Computational errors in assessment were held rectifiable as apparent from record, since deduction under s.80-IA was disallowed twice to the extent already added via TP adjustment, Chapter VI-A deduction and MAT credit were wrongly computed, and income was taken from s.143(1) intimation instead of revised return; AO was directed to rectify and recompute demand/refund. In TP for management support services, functionally dissimilar/government and credit-rating comparables were excluded, resulting in assessee&#039;s margin being at arm&#039;s length; TP adjustment was deleted. Reimbursement of software costs from AEs at cost was held not to warrant mark-up; adjustment was deleted. SEB rate (not IEX) was adopted for captive power transfers; related TP adj.....</description>
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    <pubDate>Sat, 20 Dec 2025 07:45:34 +0530</pubDate>
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      <title>Transfer pricing on management services, software reimbursements and captive power rates; s.80-IA/MAT assessment errors corrected, adjustments deleted</title>
      <link>https://www.taxtmi.com/highlights?id=95238</link>
      <description>Computational errors in assessment were held rectifiable as apparent from record, since deduction under s.80-IA was disallowed twice to the extent already added via TP adjustment, Chapter VI-A deduction and MAT credit were wrongly computed, and income was taken from s.143(1) intimation instead of revised return; AO was directed to rectify and recompute demand/refund. In TP for management support services, functionally dissimilar/government and credit-rating comparables were excluded, resulting in assessee&#039;s margin being at arm&#039;s length; TP adjustment was deleted. Reimbursement of software costs from AEs at cost was held not to warrant mark-up; adjustment was deleted. SEB rate (not IEX) was adopted for captive power transfers; related TP adj.....</description>
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      <pubDate>Sat, 20 Dec 2025 07:45:34 +0530</pubDate>
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