Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Method of valuation - It is observed that the adjudicating authority has wrongly interpreted the Board Circular. As per the Circular, when there is independent sale along with sale to ‘related persons’, Rule 9 is not applicable and recourse will have to be taken to the residuary Rule 11. - AT
Method of valuation - It is observed that the adjudicating authority has wrongly interpreted the Board Circular. As per the Circular, when there is independent sale along with sale to ‘related persons’, Rule 9 is not applicable and recourse will have to be taken to the residuary Rule 11. - AT
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