Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Disallowance of assessee’s claim in respect of its liquidated damages - Revenue argument that these liquidated damages are only in the nature of a provision is unacceptable - allowed as expenditure - AT
Disallowance of assessee’s claim in respect of its liquidated damages - Revenue argument that these liquidated damages are only in the nature of a provision is unacceptable - allowed as expenditure - AT
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