Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Rejection of books u/s 145 - Addition on account of alleged under-invoicing of sales made - There is no evidence or explanation as to why it has sold the items less than the purchase price by making loss of ₹ 38.40 per kg which resulted in under invoicing - assessee is unable to substantiate its claim with any evidence or valid explanation.
Rejection of books u/s 145 - Addition on account of alleged under-invoicing of sales made - There is no evidence or explanation as to why it has sold the items less than the purchase price by making loss of ₹ 38.40 per kg which resulted in under invoicing - assessee is unable to substantiate its claim with any evidence or valid explanation.
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