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    <title>2026 (6) TMI 722 - ITAT CHENNAI</title>
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    <description>DSIR-certified capital scientific research expenditure qualified for the weighted deduction under section 35(2AB), and the denial of that additional benefit was set aside. Uncertified capital scientific research expenditure was also allowable as a normal deduction under section 35(1)(iv) where the research nexus was established by records and auditor-certified disclosures, so the disallowance was deleted. The transfer pricing adjustment underlying the section 80IC disallowance was found unsustainable because the Revenue relied on profit comparisons without a proper comparability analysis, including product mix, segmental differences and inter-unit transfer characteristics; the deduction was therefore upheld.</description>
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      <description>DSIR-certified capital scientific research expenditure qualified for the weighted deduction under section 35(2AB), and the denial of that additional benefit was set aside. Uncertified capital scientific research expenditure was also allowable as a normal deduction under section 35(1)(iv) where the research nexus was established by records and auditor-certified disclosures, so the disallowance was deleted. The transfer pricing adjustment underlying the section 80IC disallowance was found unsustainable because the Revenue relied on profit comparisons without a proper comparability analysis, including product mix, segmental differences and inter-unit transfer characteristics; the deduction was therefore upheld.</description>
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