Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Transactions in respect of which the impugned payments were made was purely on account of services and there is no transfer of right to use the goods - No TDS u/s 195 as as the same is not royalty - AT
Transactions in respect of which the impugned payments were made was purely on account of services and there is no transfer of right to use the goods - No TDS u/s 195 as as the same is not royalty - AT
Note: It is a system-generated summary and is for quick reference only.