SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are examined.

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....SEZ-unit profit deduction extends to a voluntary transfer-pricing adjustment disclosed in the return; a pending special leave petition does not displace prevailing Tribunal and jurisdictional High Court authority without a contrary Supreme Court ruling. Ad hoc expenditure disallowance linked to exempt mutual-fund dividend income is addressed through prior assessee-specific rulings. Year-end foreign-exchange loss recognised at the balance-sheet date is treated as allowable business expenditure. In ITeS benchmarking, service providers may be excluded for functional dissimilarity, unavailable segmental information, or failure of the employee-cost filter; medical transcription, billing and coding activities are functionally distinct from the tested ITeS services.....