Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Revision u/s 263 - speculative loss in view of Section 43(5) - transactions were duly backed by contract notes, transactions were entered into by account payee cheque. The assessee proved that MCA Stock Exchange Ltd was notified for the purpose of section 43(5) of the Act - currency derivative loss is not a speculation loss.
Revision u/s 263 - speculative loss in view of Section 43(5) - transactions were duly backed by contract notes, transactions were entered into by account payee cheque. The assessee proved that MCA Stock Exchange Ltd was notified for the purpose of section 43(5) of the Act - currency derivative loss is not a speculation loss.
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