Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Revision u/s 263 - AO while completing the assessment u/s 143(3) never applied his mind to various issues as pointed out by the CIT - revision upheld - AT
Revision u/s 263 - AO while completing the assessment u/s 143(3) never applied his mind to various issues as pointed out by the CIT - revision upheld - AT
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