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    <title>2026 (5) TMI 215 - ITAT DELHI</title>
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    <description>Working capital adjustment in software development services was remitted to the AO/TPO for reconsideration on the basis of segment-wise data already furnished by the assessee. In the logistics segment, once a composite TNMM benchmarking approach was accepted, separate ALP adjustments for royalty and Global Accounts Manager charges were held impermissible because those costs were already embedded in operating cost. A CSR-linked donation did not lose deduction under section 80G merely because it formed part of CSR expenditure, and denial on that basis would amount to double disallowance. TDS/TCS credit and the section 43B disallowance were both restored for verification and fresh adjudication.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791013</link>
      <description>Working capital adjustment in software development services was remitted to the AO/TPO for reconsideration on the basis of segment-wise data already furnished by the assessee. In the logistics segment, once a composite TNMM benchmarking approach was accepted, separate ALP adjustments for royalty and Global Accounts Manager charges were held impermissible because those costs were already embedded in operating cost. A CSR-linked donation did not lose deduction under section 80G merely because it formed part of CSR expenditure, and denial on that basis would amount to double disallowance. TDS/TCS credit and the section 43B disallowance were both restored for verification and fresh adjudication.</description>
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