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    <title>Transfer Pricing Comparable Selection: specified comparables ordered included, one excluded for functional dissimilarity and ECB interest deleted.</title>
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    <description>Directives address transfer pricing comparables and an ECB interest adjustment: three comparables newly available are to be included in the TP study and one additional comparable (previously directed) must be included; one comparable is to be excluded as functionally dissimilar because it serves specialized defence R&amp;D activities unlike the taxpayer&#039;s telecom operations; an interest addition on unsecured related-party external commercial borrowing is deleted by application of the consistency principle since identical borrowings and interest were accepted in earlier years. Outcomes: include specified comparables, exclude the functionally dissimilar comparable, and delete the ECB interest adjustment.</description>
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    <pubDate>Thu, 26 Feb 2026 07:35:37 +0530</pubDate>
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      <title>Transfer Pricing Comparable Selection: specified comparables ordered included, one excluded for functional dissimilarity and ECB interest deleted.</title>
      <link>https://www.taxtmi.com/highlights?id=97195</link>
      <description>Directives address transfer pricing comparables and an ECB interest adjustment: three comparables newly available are to be included in the TP study and one additional comparable (previously directed) must be included; one comparable is to be excluded as functionally dissimilar because it serves specialized defence R&amp;D activities unlike the taxpayer&#039;s telecom operations; an interest addition on unsecured related-party external commercial borrowing is deleted by application of the consistency principle since identical borrowings and interest were accepted in earlier years. Outcomes: include specified comparables, exclude the functionally dissimilar comparable, and delete the ECB interest adjustment.</description>
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      <pubDate>Thu, 26 Feb 2026 07:35:37 +0530</pubDate>
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