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    <title>2026 (6) TMI 548 - ITAT KOLKATA</title>
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    <description>AMP, marketing, research and training outlays incurred for the assessee&#039;s own business were treated as outside transfer pricing adjustment absent proof of a separate cross-border arrangement; related adjustments were deleted. Intra-group services required fresh arm&#039;s length examination for the disputed balance. Royalty for non-exclusive use of technology, trademarks and know-how was held revenue in nature, and depreciation on electrical fittings, balance additional depreciation, and deduction for scientific research expenditure were allowed. CSR-linked donations, section 32AC investment in dealer-installed machines, treaty-limited dividend distribution tax relief, and claims for bad debt and foreign tax credit not raised in the return were remanded or allowed subject to verification. Duty drawback was taxed on receipt basis following past acceptance.</description>
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      <description>AMP, marketing, research and training outlays incurred for the assessee&#039;s own business were treated as outside transfer pricing adjustment absent proof of a separate cross-border arrangement; related adjustments were deleted. Intra-group services required fresh arm&#039;s length examination for the disputed balance. Royalty for non-exclusive use of technology, trademarks and know-how was held revenue in nature, and depreciation on electrical fittings, balance additional depreciation, and deduction for scientific research expenditure were allowed. CSR-linked donations, section 32AC investment in dealer-installed machines, treaty-limited dividend distribution tax relief, and claims for bad debt and foreign tax credit not raised in the return were remanded or allowed subject to verification. Duty drawback was taxed on receipt basis following past acceptance.</description>
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