Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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TP Adjustment - Interest on External Commercial Borrowing (ECB) - The Tribunal found that the term of the ECB loan was indeed five years, not four years as asserted by the Revenue authorities. Considering past acceptance of similar interest rates by the TPO, the Tribunal ruled in favor of the assessee, allowing the interest payment on ECBs at the claimed rate.
TP Adjustment - Interest on External Commercial Borrowing (ECB) - The Tribunal found that the term of the ECB loan was indeed five years, not four years as asserted by the Revenue authorities. Considering past acceptance of similar interest rates by the TPO, the Tribunal ruled in favor of the assessee, allowing the interest payment on ECBs at the claimed rate.
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