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    <title>2026 (6) TMI 864 - ITAT AHMEDABAD</title>
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    <description>Where international transactions are benchmarked under TNMM and a working capital adjustment has already been granted, delayed receivables are ordinarily subsumed in the arm&#039;s length analysis and do not warrant a separate notional interest adjustment absent an independent financing arrangement; the transfer pricing addition was deleted. Deduction under section 80G is not barred merely because a donation is made as part of CSR expenditure, but eligibility and compliance with statutory conditions, including recipient approval, required fresh verification and the issue was remanded. The claim for refund of excess dividend distribution tax also required fresh adjudication because it had not been examined by the lower authorities.</description>
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