Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Rejection of books of accounts - difference in the opening stock as well as the closing stock - the assessee has shown excess opening stock - The AO did not care to consider that whether the assessee is having the above stock as actual stock with the assessee and if so what is the source of investment for the above stock. The Assessing Officer has not even examined the source of stock nor was such stock found during the course of survey - No purchase vouchers or details were also found during the course of survey - CIT(A) rightly deleted the additions - AT
Rejection of books of accounts - difference in the opening stock as well as the closing stock - the assessee has shown excess opening stock - The AO did not care to consider that whether the assessee is having the above stock as actual stock with the assessee and if so what is the source of investment for the above stock. The Assessing Officer has not even examined the source of stock nor was such stock found during the course of survey - No purchase vouchers or details were also found during the course of survey - CIT(A) rightly deleted the additions - AT
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