Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Disallowance under section 40(a)(ia) - secondment of employees to the assessee in India - such reimbursement of expenses are not income in the hands of the non-resident and therefore, TDS provisions are not applicable. - AT
Disallowance under section 40(a)(ia) - secondment of employees to the assessee in India - such reimbursement of expenses are not income in the hands of the non-resident and therefore, TDS provisions are not applicable. - AT
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