Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Rejection of VCES application - The Revenue has only taken a different interpretation as far as the classification of services. This cannot tantamount to substantial misdeclaration - tax liability accepted in the VCES by the appellant is not being interfered - AT
Rejection of VCES application - The Revenue has only taken a different interpretation as far as the classification of services. This cannot tantamount to substantial misdeclaration - tax liability accepted in the VCES by the appellant is not being interfered - AT
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