Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Reopening of assessment u/s 147 - period of limitation - The appellant having enjoyed the benefit of the interim order passed by the Hon'ble Supreme Court on 08.12.2016, restoring the position, which stood as on 08.06.2014, are not entitled to maintain a challenge to the reopening/reassessment on the ground of limitation. - HC
Reopening of assessment u/s 147 - period of limitation - The appellant having enjoyed the benefit of the interim order passed by the Hon'ble Supreme Court on 08.12.2016, restoring the position, which stood as on 08.06.2014, are not entitled to maintain a challenge to the reopening/reassessment on the ground of limitation. - HC
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