Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Rectification in transfer pricing proceedings was required where the assessee claimed that an international transaction had been wrongly allocated between segments and sought corrected segmental financials; the matter was remitted for verification and fresh decision after hearing. Comparable margins, as well as working capital and risk adjustments, were also restored for examination by the AO/TPO, with no merits adjudicated and all surviving transfer pricing grounds sent back for fresh adjudication.
Rectification in transfer pricing proceedings was required where the assessee claimed that an international transaction had been wrongly allocated between segments and sought corrected segmental financials; the matter was remitted for verification and fresh decision after hearing. Comparable margins, as well as working capital and risk adjustments, were also restored for examination by the AO/TPO, with no merits adjudicated and all surviving transfer pricing grounds sent back for fresh adjudication.
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