Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Rejection of SVLDRS-1 -Quantifiation of demand - It is evident that there was a quantification by the audit Department on 31.05.2019 based on which the petitioner has filed Form SVLDRS-1 dated 07.11.2019 under the category "Investigation, Enquiry or Audit" Subcategory Audit. It cannot therefore be construed that there was no determination of tax liability of the petitioner on or before 30.06.2019. - Application directed to be accepted. - HC
Rejection of SVLDRS-1 -Quantifiation of demand - It is evident that there was a quantification by the audit Department on 31.05.2019 based on which the petitioner has filed Form SVLDRS-1 dated 07.11.2019 under the category "Investigation, Enquiry or Audit" Subcategory Audit. It cannot therefore be construed that there was no determination of tax liability of the petitioner on or before 30.06.2019. - Application directed to be accepted. - HC
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