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...
Date of applicability of new policy - transfer of DIFA - Inasmuch as the circular in clear terms clarifies that the amendments made in the Policy would not be applicable to the authorization issued prior to 1.4.07, we are of the view that confirmation of demand against the appellants is not justified - AT
Date of applicability of new policy - transfer of DIFA - Inasmuch as the circular in clear terms clarifies that the amendments made in the Policy would not be applicable to the authorization issued prior to 1.4.07, we are of the view that confirmation of demand against the appellants is not justified - AT
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