Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Disallowance on account of Foreign Fluctuation Exchange loss - such loss/profit to be of revenue character. - the CBDT Instruction cannot override the judicially settled position - claim allowed.
Disallowance on account of Foreign Fluctuation Exchange loss - such loss/profit to be of revenue character. - the CBDT Instruction cannot override the judicially settled position - claim allowed.
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