Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
The HC held that the show cause notice u/s 18 was valid, but set aside the notice u/s 28(4) as authorities failed to conduct provisional assessment before issuance. The petitioner was granted six weeks to reply to the Section 18 notice.
The HC held that the show cause notice u/s 18 was valid, but set aside the notice u/s 28(4) as authorities failed to conduct provisional assessment before issuance. The petitioner was granted six weeks to reply to the Section 18 notice.
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