Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
If assessee was not liable to pay the tax in question, the department had no business to retain it even if it was wrongly paid - In case it is not a case of Revision u/s 264, authorities could have invoked section 119.
If assessee was not liable to pay the tax in question, the department had no business to retain it even if it was wrongly paid - In case it is not a case of Revision u/s 264, authorities could have invoked section 119.
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