Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Disallowance of interest expense - loan and advances to sister concerns – Held that:- Rate of interest for advancing the loan to the sister concern was 6% and borrowing in the majority cases was at 12% - no disallowance - HC
Disallowance of interest expense - loan and advances to sister concerns – Held that:- Rate of interest for advancing the loan to the sister concern was 6% and borrowing in the majority cases was at 12% - no disallowance - HC
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