Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Clandestine Removal - statements recorded by Revenue - The Commissioner has clearly ignored this findings and come to a difference conclusion. While doing so he is relied on the confessional statements of buyers. There are no opportunity of cross-examination has been given and the test of Section 9D of the Central Excise Act has not been passed in respect of this statements. In absence of cross-examination no reliance can be placed on these statements. - AT
Clandestine Removal - statements recorded by Revenue - The Commissioner has clearly ignored this findings and come to a difference conclusion. While doing so he is relied on the confessional statements of buyers. There are no opportunity of cross-examination has been given and the test of Section 9D of the Central Excise Act has not been passed in respect of this statements. In absence of cross-examination no reliance can be placed on these statements. - AT
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