Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Validity of Search u/s 132 - suppression of income as the profit declared is contrary to the actual profit received. - The power for re-assessment is no doubt a remedy available to the Authority but in light of the information as detailed in the note, grounds have been made out for exercise of power u/s 132(c) in the present case and it cannot be said that the said action is either malafide/ arbitrary/ capricious. - HC
Validity of Search u/s 132 - suppression of income as the profit declared is contrary to the actual profit received. - The power for re-assessment is no doubt a remedy available to the Authority but in light of the information as detailed in the note, grounds have been made out for exercise of power u/s 132(c) in the present case and it cannot be said that the said action is either malafide/ arbitrary/ capricious. - HC
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