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    <title>Reliable comparables and APA benchmarking in transfer pricing: unreliable accounts justified exclusion, and support-service adjustment was deleted.</title>
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    <description>Financial irregularities found by SEBI rendered Acropetal Technologies Ltd.&#039;s accounts and margins unreliable, so its exclusion from the comparables set was upheld for transfer pricing purposes. The Tribunal noted that diversion of funds to non-business use can materially distort operating margins and followed prior co-ordinate bench decisions excluding the same company. For intra-group support services, it accepted that a later APA margin could have persuasive value for a non-APA year where the transactions were identical, the FAR profile was unchanged, and documentary evidence supported receipt of services. The transfer pricing adjustment on support services was therefore deleted.</description>
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    <pubDate>Mon, 29 Jun 2026 09:28:31 +0530</pubDate>
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      <title>Reliable comparables and APA benchmarking in transfer pricing: unreliable accounts justified exclusion, and support-service adjustment was deleted.</title>
      <link>https://www.taxtmi.com/highlights?id=101189</link>
      <description>Financial irregularities found by SEBI rendered Acropetal Technologies Ltd.&#039;s accounts and margins unreliable, so its exclusion from the comparables set was upheld for transfer pricing purposes. The Tribunal noted that diversion of funds to non-business use can materially distort operating margins and followed prior co-ordinate bench decisions excluding the same company. For intra-group support services, it accepted that a later APA margin could have persuasive value for a non-APA year where the transactions were identical, the FAR profile was unchanged, and documentary evidence supported receipt of services. The transfer pricing adjustment on support services was therefore deleted.</description>
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