Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Doctrine of Res judicata – There is no question of its being a res judicata so as to bind the A.O. appellate authority or the Tribunal in tax matters so as to decide the matter according to the past transaction only. - HC
Doctrine of Res judicata – There is no question of its being a res judicata so as to bind the A.O. appellate authority or the Tribunal in tax matters so as to decide the matter according to the past transaction only. - HC
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