Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
TDS u/s 194A - IPO - other borrowing cost and financial charges - Inasmuch as the liability is not depending upon the debt or CCDs, but contingent upon the happening of the IPO, such payment cannot be called as payment of interest. Consequently, the provisions under section 194A or 40(a)(ia) of the Act are not attracted. - AT
TDS u/s 194A - IPO - other borrowing cost and financial charges - Inasmuch as the liability is not depending upon the debt or CCDs, but contingent upon the happening of the IPO, such payment cannot be called as payment of interest. Consequently, the provisions under section 194A or 40(a)(ia) of the Act are not attracted. - AT
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