Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Deduction u/s 36(1)(viia) or u/s 36(1)(viii) - creation of special reserve fund - the assessee has tried to equate the apportionment of profit against an expenditure for provision for bad and doubtful debts which in our view is not possible.
Deduction u/s 36(1)(viia) or u/s 36(1)(viii) - creation of special reserve fund - the assessee has tried to equate the apportionment of profit against an expenditure for provision for bad and doubtful debts which in our view is not possible.
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