Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Accrual of income in India - TP Adjustment - when the amount remunerated by the assessee is found to be satisfying the ‘arms length’ principle, therefore, no further profits could be attributed to the assessee in India even if it was to be held that the latter had a PE in India
Accrual of income in India - TP Adjustment - when the amount remunerated by the assessee is found to be satisfying the ‘arms length’ principle, therefore, no further profits could be attributed to the assessee in India even if it was to be held that the latter had a PE in India
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