Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Reopening of assessment u/s 147 - validity of reasons to believe - The non-rejection of the explanation in the Assessment Order would amount to the Assessing Officer accepting the view of the assessee, thus taking a view/forming an opinion. - SC uphold the order of HC
Reopening of assessment u/s 147 - validity of reasons to believe - The non-rejection of the explanation in the Assessment Order would amount to the Assessing Officer accepting the view of the assessee, thus taking a view/forming an opinion. - SC uphold the order of HC
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