Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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TP adjsutment - “AE” investment banking activities - comparable selection - The persistence loss- making company are normally excluded as comparable. As per the submission of assessee both the companies are made profit in relevant years. DR did not strongly object on the plea of assessee. No objection was made by the ld DR in factual position. So, these companies should not be excluded on the ground of loss-making company. - AT
TP adjsutment - “AE” investment banking activities - comparable selection - The persistence loss- making company are normally excluded as comparable. As per the submission of assessee both the companies are made profit in relevant years. DR did not strongly object on the plea of assessee. No objection was made by the ld DR in factual position. So, these companies should not be excluded on the ground of loss-making company. - AT
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