Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
The period in question is beyond the period of five years. It is a settled position that no demand can be raised beyond the period of five years. The assessee is correct in saying that the show cause notice is barred by time and is unsustainable. - AT
The period in question is beyond the period of five years. It is a settled position that no demand can be raised beyond the period of five years. The assessee is correct in saying that the show cause notice is barred by time and is unsustainable. - AT
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