Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Since the effective control and possession of the equipments were not transferred to the appellant-assessee, as per the statutory mandates, such use of the equipment belonging to M/s BHEL cannot not be leviable to service tax under the category of “ Supply of Tangible Goods Service”.
Since the effective control and possession of the equipments were not transferred to the appellant-assessee, as per the statutory mandates, such use of the equipment belonging to M/s BHEL cannot not be leviable to service tax under the category of “ Supply of Tangible Goods Service”.
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