Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Disallowance under section 40A(3) - Cash purchase - cash payments through truck drivers - According to the assessee, the truck driver acts as an agent of the assessee. - There is no privity of contract between the person receiving the sums in cash and the assessee and the truck driver. Such payments are not protected under rule 6 DD (k) of the Rules. On this premise, we reject contention of the assessee. - AT
Disallowance under section 40A(3) - Cash purchase - cash payments through truck drivers - According to the assessee, the truck driver acts as an agent of the assessee. - There is no privity of contract between the person receiving the sums in cash and the assessee and the truck driver. Such payments are not protected under rule 6 DD (k) of the Rules. On this premise, we reject contention of the assessee. - AT
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