Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Merely because the adjudicating authority has given an elaborate finding, it does not mean that the appellate authority need not discuss the matter and give a finding. Such an approach makes a mockery of the appeal proceedings - AT
Merely because the adjudicating authority has given an elaborate finding, it does not mean that the appellate authority need not discuss the matter and give a finding. Such an approach makes a mockery of the appeal proceedings - AT
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