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...
TDS u/s 195 - in the absence of the PE in India, the business profit of the non-resident is not taxable in India. - even if it is considered that the payments made to non-resident will fall under Article 22 of the Treaty viz. “Other Income“, then also not taxable in India - AT
TDS u/s 195 - in the absence of the PE in India, the business profit of the non-resident is not taxable in India. - even if it is considered that the payments made to non-resident will fall under Article 22 of the Treaty viz. “Other Income“, then also not taxable in India - AT
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