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    <description>Transfer pricing adjustments for management fees should follow the consistency principle where materially identical facts have previously led to deletion of similar adjustments. On that basis, no separate management-fee adjustment was warranted. Alleged double additions arising during return processing require factual verification where an amount may already have been disallowed in the taxpayer&#039;s computation; the matter should be examined by the Assessing Officer. Short credit for tax deducted at source and interest charged for delayed return filing also require verification, including whether the return was filed within an extended due date, with consequential relief where admissible after hearing the taxpayer.</description>
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