Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Interim order directing release of goods upon depositing Rs. 4 lakhs challenged. Considering the order, determined liability of Rs. 22,35,932/- on respondent No. 1, and total goods value of Rs. 12,83,354/-, appeal disposed by upholding the order. Additionally, respondent No. 1 directed to furnish a Bank Guarantee from a Nationalized Bank for Rs. 8,83,354/- in favor of the Joint Commissioner of Commercial Taxes (Vigilance), valid during the pendency of the writ petition. Respondent No. 1 also required to furnish a personal bond of Mr. Chikka Aanjibabu, Proprietor, within two days to enable appellants to release goods and conveyance as per the Single Judge's direction, subject to the writ petition's outcome.
Interim order directing release of goods upon depositing Rs. 4 lakhs challenged. Considering the order, determined liability of Rs. 22,35,932/- on respondent No. 1, and total goods value of Rs. 12,83,354/-, appeal disposed by upholding the order. Additionally, respondent No. 1 directed to furnish a Bank Guarantee from a Nationalized Bank for Rs. 8,83,354/- in favor of the Joint Commissioner of Commercial Taxes (Vigilance), valid during the pendency of the writ petition. Respondent No. 1 also required to furnish a personal bond of Mr. Chikka Aanjibabu, Proprietor, within two days to enable appellants to release goods and conveyance as per the Single Judge's direction, subject to the writ petition's outcome.
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