Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Validity of reopening of assessment - period of limitation to issue notice - validity of a notice issued under Section 148/148A - scope of Taxation and other laws (Relaxation and Amendment of certain provisions) Act, 2020 (TOLA) application - The High Court refers to a previous judgment and concludes that the notices issued for the Assessment Year 2013-2014 are barred by limitation due to the amendments to the Finance Act and the provisions existing prior to the amendment. - The Court specifically addresses various contentions raised by the Department regarding the applicability of different legal provisions and notifications, ultimately ruling in favor of the petitioners.
Validity of reopening of assessment - period of limitation to issue notice - validity of a notice issued under Section 148/148A - scope of Taxation and other laws (Relaxation and Amendment of certain provisions) Act, 2020 (TOLA) application - The High Court refers to a previous judgment and concludes that the notices issued for the Assessment Year 2013-2014 are barred by limitation due to the amendments to the Finance Act and the provisions existing prior to the amendment. - The Court specifically addresses various contentions raised by the Department regarding the applicability of different legal provisions and notifications, ultimately ruling in favor of the petitioners.
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