Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Commercial Training or Coaching Services - appellant is a PSU mainly engaged in the activity of ship building and repair works - The lower authority seemed to have lost sight of the factual position that the subject courses have been approved by the Director General of Shipping, Ministry of Surface Transport, Govt. of India, in consonance with the provisions of the Merchant Shipping Act, 1958, a fact which was always available before them - There cannot be any iota of doubt to hold that the courses assumes to be of statutory nature and hence, qualifies as being “recognised under the law”
Commercial Training or Coaching Services - appellant is a PSU mainly engaged in the activity of ship building and repair works - The lower authority seemed to have lost sight of the factual position that the subject courses have been approved by the Director General of Shipping, Ministry of Surface Transport, Govt. of India, in consonance with the provisions of the Merchant Shipping Act, 1958, a fact which was always available before them - There cannot be any iota of doubt to hold that the courses assumes to be of statutory nature and hence, qualifies as being “recognised under the law”
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