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    <title>2025 (3) TMI 1647 - ITAT DELHI</title>
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    <description>Transfer pricing disputes concerning intra-group services were restored for fresh adjudication, while royalty computation was directed to be redone under the applicable percentile method. Support service expenditure was deleted following earlier tribunal findings on a recurring issue. Annual revenue share-based licence fee was held amortisable under section 35ABB, with consequential computation left open. CSR-related donation was held eligible for deduction under section 80G. Road tax and VAT on leased assets were allowed as revenue expenditure, and the appellate claim was entertained even though it was not raised in the return. The jurisdictional challenge to the final assessment order failed.</description>
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