Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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The assessee, a trust governed by the Government of India, was held eligible for exemption u/s 11 of the Act for arranging credit guarantees to small ventures and supporting business/livelihood development. The ITAT allowed the ground taken by the assessee, following its previous order. The provision for guarantee claims created against outstanding guarantees was treated as an allowable expense, being necessary for providing effective credit guarantees to small and medium enterprises without collateral security through eligible banks as per the scheme.
The assessee, a trust governed by the Government of India, was held eligible for exemption u/s 11 of the Act for arranging credit guarantees to small ventures and supporting business/livelihood development. The ITAT allowed the ground taken by the assessee, following its previous order. The provision for guarantee claims created against outstanding guarantees was treated as an allowable expense, being necessary for providing effective credit guarantees to small and medium enterprises without collateral security through eligible banks as per the scheme.
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