Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Extended period of limitation - PSU - The Tribunal noted that the demand for interest was raised beyond the statutory limitation period. It was emphasized that since the appellant was a State Government Undertaking, the element of suppression of facts and malafide intention did not apply.
Extended period of limitation - PSU - The Tribunal noted that the demand for interest was raised beyond the statutory limitation period. It was emphasized that since the appellant was a State Government Undertaking, the element of suppression of facts and malafide intention did not apply.
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