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...
When the appellant did not avail opportunity to reconcile the figures and guide the authorities below as to which figure shall govern the appellant, there is no necessity to remand the matter for further opportunity. - AT
When the appellant did not avail opportunity to reconcile the figures and guide the authorities below as to which figure shall govern the appellant, there is no necessity to remand the matter for further opportunity. - AT
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