Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Without having itself seen the books, the latter observation made by the Tribunal cannot be sustained. Being a fact finding authority and the rejection of books of account being an issue raised before it, Tribunal was bound to return a proper finding upon appraisal of material and evidence.
Without having itself seen the books, the latter observation made by the Tribunal cannot be sustained. Being a fact finding authority and the rejection of books of account being an issue raised before it, Tribunal was bound to return a proper finding upon appraisal of material and evidence.
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