Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Leakage of revenue - Any disallowance should be specific and properly quantified - presumptive and ad-hoc addition based on an outlandish consideration of plugging possible leakage or revenue deleted - AT
Leakage of revenue - Any disallowance should be specific and properly quantified - presumptive and ad-hoc addition based on an outlandish consideration of plugging possible leakage or revenue deleted - AT
Note: It is a system-generated summary and is for quick reference only.