Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Assessment u/s 143(3) r.w.s 144C - Period of limitation u/s 153 - Issuance of direction by the JCIT u/s 144A - The issuance of the direction and the communication of such direction by the Joint Commissioner to the assessing officer to aid in the completion of assessment is expected to be within the overall limits provided for completion of assessment under Section 153 and Explanation (1) thereto and nowhere it is contemplated that such reference would extend the limitation. - HC
Assessment u/s 143(3) r.w.s 144C - Period of limitation u/s 153 - Issuance of direction by the JCIT u/s 144A - The issuance of the direction and the communication of such direction by the Joint Commissioner to the assessing officer to aid in the completion of assessment is expected to be within the overall limits provided for completion of assessment under Section 153 and Explanation (1) thereto and nowhere it is contemplated that such reference would extend the limitation. - HC
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