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    <title>Transfer Pricing: royalty adjustment negated by prior appellate precedent; typographical error did not defeat infrastructure deduction claim.</title>
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    <description>Transfer pricing issue concerned royalty paid to an associated enterprise where the adjustment was negated in favour of the taxpayer because the earlier appellate decision in the taxpayer&#039;s own case on the same issue precluded fresh adjustment; the assessing officer had relied on a prior TPO finding but the appellate precedent established nil ALP, resulting in relief. Separately, claim for deduction under the industrial/infrastructure undertaking provision for participation in a micro irrigation project was allowed after the taxpayer produced execution copies, invoices, payments and certificates; a typographical error in the agreement party name was held not to defeat entitlement and the revenue failed to rebut the evidence.</description>
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    <pubDate>Tue, 03 Mar 2026 08:42:40 +0530</pubDate>
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      <title>Transfer Pricing: royalty adjustment negated by prior appellate precedent; typographical error did not defeat infrastructure deduction claim.</title>
      <link>https://www.taxtmi.com/highlights?id=97368</link>
      <description>Transfer pricing issue concerned royalty paid to an associated enterprise where the adjustment was negated in favour of the taxpayer because the earlier appellate decision in the taxpayer&#039;s own case on the same issue precluded fresh adjustment; the assessing officer had relied on a prior TPO finding but the appellate precedent established nil ALP, resulting in relief. Separately, claim for deduction under the industrial/infrastructure undertaking provision for participation in a micro irrigation project was allowed after the taxpayer produced execution copies, invoices, payments and certificates; a typographical error in the agreement party name was held not to defeat entitlement and the revenue failed to rebut the evidence.</description>
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