Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Sale and a lease back transaction - the lease transactions were genuine and that the Department failed to adduce any evidence to prove that the transaction was not genuine or was a sham no disallowance can be warranted - HC
Sale and a lease back transaction - the lease transactions were genuine and that the Department failed to adduce any evidence to prove that the transaction was not genuine or was a sham no disallowance can be warranted - HC
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