Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Addition on account of interest - capital expenditure or revenue expenditure - assessee has "parked its investible funds in the equity shares of a closely associated concern" - there was no basis for treating the interest expenditure claimed by the assessee as capital expenditure - AT
Addition on account of interest - capital expenditure or revenue expenditure - assessee has "parked its investible funds in the equity shares of a closely associated concern" - there was no basis for treating the interest expenditure claimed by the assessee as capital expenditure - AT
Note: It is a system-generated summary and is for quick reference only.