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    <description>Functionally comparable loss-making companies cannot be excluded on a rigid persistent-loss filter where the record does not show true continuous losses; the comparable was directed to be retained. Miscellaneous expenses in incomplete XBRL disclosures were treated as operating unless a specific non-operating element was proved, while government grants, test track income and incidental business receipts were held to be operating income. High-end software companies with brand value, intangibles, R&amp;D and no segmental data were held incomparable to a captive service provider, and notional interest on overdue receivables was deleted for a debt-free assessee. The tribunal also treated Ind AS unwinding of discount as non-taxable real income, allowed scientific research capital expenditure, and upheld subscription fees as deductible business ; only interest and TCS-credit verification issues were remitted.</description>
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