Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
The onus is upon the assessee to establish that the money was borrowed for the purpose of business - assessee failed to prove the onus - Claim of Interest disallowed - AT
The onus is upon the assessee to establish that the money was borrowed for the purpose of business - assessee failed to prove the onus - Claim of Interest disallowed - AT
Note: It is a system-generated summary and is for quick reference only.