Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Valuation - goods valued on the ex-factory value - supply of goods was on FOR basis - only possible criteria for the purpose is as to whether the property in goods stands transferred to the buyer at the time when the goods are cleared at manufacturer place or not - dept. has been acknowledged that all the verifications, approvals by buyer got conducted at factory itself - assessable without freight and insurance
Valuation - goods valued on the ex-factory value - supply of goods was on FOR basis - only possible criteria for the purpose is as to whether the property in goods stands transferred to the buyer at the time when the goods are cleared at manufacturer place or not - dept. has been acknowledged that all the verifications, approvals by buyer got conducted at factory itself - assessable without freight and insurance
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