Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Before making disallowance u/s 40(a)(ia), the pre-requisite conditions are that the AO should bring material on record to show that the assessee was liable to deduct tax in respect of the expenditure specified in that section - AT
Before making disallowance u/s 40(a)(ia), the pre-requisite conditions are that the AO should bring material on record to show that the assessee was liable to deduct tax in respect of the expenditure specified in that section - AT
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