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    <title>2026 (3) TMI 1481 - ITAT DELHI</title>
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    <description>ITAT Delhi dealt with multiple transfer pricing and deduction disputes, deleting the royalty adjustment on trademark and trade name use by following its own prior year ruling and rejecting the substitution of TNMM comparables. It also deleted the domestic transfer pricing adjustment on passive infrastructure charges and rent after noting the relevant provision had been omitted. Depreciation was allowed on 3G spectrum rights, Department of Telecommunication penalty, IBM-related payments, and WPC royalty expense as revenue or intangible-related claims, while prepaid distributor discounts were held not to attract section 40(a)(ia). The liabilities written back addition was sustained, and the TDS credit and refund interest issues were remitted for verification.</description>
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      <title>2026 (3) TMI 1481 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=788726</link>
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