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    <title>2026 (6) TMI 1268 - ITAT MUMBAI</title>
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    <description>Nil ALP determination for PTSE, IT support and centralised support services was deleted because the year&#039;s facts were materially identical to the assessee&#039;s earlier year, where service rendition had already been found established from agreements, invoices, emails, cost allocation workings and third-party evidence. The Tribunal treated that earlier finding as binding in the absence of any stay or reversal, and held that mere pendency of the Revenue&#039;s appeal before the High Court did not dilute its force. The transfer pricing adjustment was therefore deleted in favour of the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=793887</link>
      <description>Nil ALP determination for PTSE, IT support and centralised support services was deleted because the year&#039;s facts were materially identical to the assessee&#039;s earlier year, where service rendition had already been found established from agreements, invoices, emails, cost allocation workings and third-party evidence. The Tribunal treated that earlier finding as binding in the absence of any stay or reversal, and held that mere pendency of the Revenue&#039;s appeal before the High Court did not dilute its force. The transfer pricing adjustment was therefore deleted in favour of the assessee.</description>
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