Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Disallowance of branch transfer - Interstate sale - CST - Mere location of the dealer in Bangalore, Karnataka and appellants at Bangalore, ipso facto, would not justify a conclusion that there was a stock transfer first and thereafter a sale to the said dealer. Even then, a first sale would have taken place from a depot to the dealer in Karnataka, thereafter, a second sale from the dealer to its customer. - HC
Disallowance of branch transfer - Interstate sale - CST - Mere location of the dealer in Bangalore, Karnataka and appellants at Bangalore, ipso facto, would not justify a conclusion that there was a stock transfer first and thereafter a sale to the said dealer. Even then, a first sale would have taken place from a depot to the dealer in Karnataka, thereafter, a second sale from the dealer to its customer. - HC
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