Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Disallowance u/s 14A r.w.r. 8D - no proper recording of satisfaction by the AO for rejecting the suomoto disallowance made by the Assessee - The Tribunal found that in the current case, similar to the preceding assessment year, there was no proper recording of satisfaction by the AO for rejecting the suo moto disallowance made by the Assessee. As a result, the Tribunal allowed the Assessee's appeal and directed the AO to delete the impugned addition.
Disallowance u/s 14A r.w.r. 8D - no proper recording of satisfaction by the AO for rejecting the suomoto disallowance made by the Assessee - The Tribunal found that in the current case, similar to the preceding assessment year, there was no proper recording of satisfaction by the AO for rejecting the suo moto disallowance made by the Assessee. As a result, the Tribunal allowed the Assessee's appeal and directed the AO to delete the impugned addition.
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