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    <title>2026 (6) TMI 546 - ITAT AHMEDABAD</title>
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    <description>Entity-level TNMM was preferred over an internal Cost Plus Method where the assessee&#039;s functional profile and facts remained unchanged and its own earlier years had accepted TNMM; the transfer pricing adjustment was therefore deleted, reflecting the need to follow consistent precedent on identical facts. An intimation adjustment on reversal of provisions was treated as requiring verification because the provisions had already been disallowed on creation and could not be taxed again without checking for double taxation; the matter was remanded for limited factual examination. Short grant of TDS/TCS credit was also held to be verification-based, with credit to be allowed after examination of Form 26AS/AIS and supporting records.</description>
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      <title>2026 (6) TMI 546 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=793165</link>
      <description>Entity-level TNMM was preferred over an internal Cost Plus Method where the assessee&#039;s functional profile and facts remained unchanged and its own earlier years had accepted TNMM; the transfer pricing adjustment was therefore deleted, reflecting the need to follow consistent precedent on identical facts. An intimation adjustment on reversal of provisions was treated as requiring verification because the provisions had already been disallowed on creation and could not be taxed again without checking for double taxation; the matter was remanded for limited factual examination. Short grant of TDS/TCS credit was also held to be verification-based, with credit to be allowed after examination of Form 26AS/AIS and supporting records.</description>
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