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...
TP - The benchmarking done by the assessee are based on the interest paid by it on its own borrowings of loan in foreign currency from KEXIM bank and also from State Bank of India - The interest charged by the assessee on the loan given by it to its AE is at arm's length and no further adjustment is required - AT
TP - The benchmarking done by the assessee are based on the interest paid by it on its own borrowings of loan in foreign currency from KEXIM bank and also from State Bank of India - The interest charged by the assessee on the loan given by it to its AE is at arm's length and no further adjustment is required - AT
Note: It is a system-generated summary and is for quick reference only.
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