Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Condonation of delay in filing an appeal - eligible reasons to delay - The conduct of the assessee does not inspire the confidence and hence, we are of the considered opinion that the assessee has grossly failed to explain the reasonable cause in filing the appeal belatedly. Accordingly, we decline to condone the delay of about 18 months in filing the present appeals - AT
Condonation of delay in filing an appeal - eligible reasons to delay - The conduct of the assessee does not inspire the confidence and hence, we are of the considered opinion that the assessee has grossly failed to explain the reasonable cause in filing the appeal belatedly. Accordingly, we decline to condone the delay of about 18 months in filing the present appeals - AT
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