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    <title>2026 (1) TMI 467 - ITAT DELHI</title>
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    <description>Consistent acceptance of the assessee&#039;s transfer pricing benchmarking in earlier and later years led to deletion of the adjustment on imports, trading transactions and service fee payments, as the Tribunal applied the principle of consistency on identical facts. The foreign travel claim was not fully supported by complete details and the initial disallowance was ad hoc, so a partial disallowance of 10% was retained. The disallowance under section 40(a)(i) for allocated expenses was deleted because the Revenue had not identified the actual payments accruing during the year and the facts matched the assessee&#039;s earlier year position.</description>
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