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...
Whether the payment of 'discount' and 'rebate' was subject to deduction of TDS – There was 'agency agreement' - Certain incentives as given by the assessee did not constitute a ‘commission’; hence, out of the purview of the provisions of Section 194H - AT
Whether the payment of 'discount' and 'rebate' was subject to deduction of TDS – There was 'agency agreement' - Certain incentives as given by the assessee did not constitute a ‘commission’; hence, out of the purview of the provisions of Section 194H - AT
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