Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Eligibility to claim credit for the tax deducted in Japan - the treatment sought to be given by Revenue in the case of the assessee yields absurd result - Accordingly assessee should be treated to have paid tax in India without giving effect to the provision of section 10A for the reason also of Article 24 of Double Taxation Avoidance Convention between India and Japan. - AT
Eligibility to claim credit for the tax deducted in Japan - the treatment sought to be given by Revenue in the case of the assessee yields absurd result - Accordingly assessee should be treated to have paid tax in India without giving effect to the provision of section 10A for the reason also of Article 24 of Double Taxation Avoidance Convention between India and Japan. - AT
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