Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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The credit in the “Dealers Spare Part Account” received by the Petitioner can be treated as actual Sale price received by the Appellant for replacement of spares during the manufacturer's warranty scheme, since no reimbursement is received from MUL.
The credit in the “Dealers Spare Part Account” received by the Petitioner can be treated as actual Sale price received by the Appellant for replacement of spares during the manufacturer's warranty scheme, since no reimbursement is received from MUL.
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