DSIR-approved R&D deduction and APA-aligned transfer pricing adjustments were limited, while double disallowance was rejected.

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....DSIR-approved in-house R&D deduction cannot be disallowed by the AO or DRP on the basis of survey statements once the prescribed authority has quantified the eligible expenditure; later survey findings do not unsettle earlier certified claims. Where procurement commission had already been benchmarked in transfer pricing proceedings, a further disallowance under the normal provisions was treated as impermissible double disallowance, absent evidence that the payment was sham. On APA-consistent transactions, the raw material purchase adjustment was restricted and the corporate guarantee adjustment was deleted or capped. Litigation provision, Chapter VI-A deduction and TDS credit issues were remitted for verification, with interest consequential and penalty premature.....