Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Penalty u/s 76 & 78 - Entire amount due paid before issuance of SCN - case was also covered by Section 73(3) of the Finance Act 1994 and there was no need to issue show cause notice in this case. Appellant is also eligible for the benefit of Section 80 of the Finance Act 1994 - AT
Penalty u/s 76 & 78 - Entire amount due paid before issuance of SCN - case was also covered by Section 73(3) of the Finance Act 1994 and there was no need to issue show cause notice in this case. Appellant is also eligible for the benefit of Section 80 of the Finance Act 1994 - AT
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