Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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30% ad-hoc disallowance of travelling expenses being car charges, foreign travelling expenses and domestic travelling expenses - The Assessee argued that the expenses were essential for business expansion and were supported by legal justifications, including past judicial decisions. - The Tribunal concluded that the Lower Authorities erred in making ad-hoc disallowance without disputing the genuineness of the expenses.
30% ad-hoc disallowance of travelling expenses being car charges, foreign travelling expenses and domestic travelling expenses - The Assessee argued that the expenses were essential for business expansion and were supported by legal justifications, including past judicial decisions. - The Tribunal concluded that the Lower Authorities erred in making ad-hoc disallowance without disputing the genuineness of the expenses.
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