Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Refund application rejected - export of consignments - period of limitation - co-relation should have been properly explained by the appellants to the lower authorities which has not been done so, thus issue needs reconsideration - AT
Refund application rejected - export of consignments - period of limitation - co-relation should have been properly explained by the appellants to the lower authorities which has not been done so, thus issue needs reconsideration - AT
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