Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Franchise service or not - appellant has entered into agreements with various independent bottlers who possesses the necessary licenses for manufacturing of alcoholic liquors - the appellant being brand owner and earned the profit/surplus, the same being in nature of business profit and the same is not chargeable to service tax - Benefit of circular, even if withdrawn, extended.
Franchise service or not - appellant has entered into agreements with various independent bottlers who possesses the necessary licenses for manufacturing of alcoholic liquors - the appellant being brand owner and earned the profit/surplus, the same being in nature of business profit and the same is not chargeable to service tax - Benefit of circular, even if withdrawn, extended.
Note: It is a system-generated summary and is for quick reference only.
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