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...
Transfer pricing adjustment - Offshore activities – The fabrication and supplies are made by the third parties outside India to the assessee and the revenue is not taxing the profits of these third parties - matter remanded back for verification of facts - AT
Transfer pricing adjustment - Offshore activities – The fabrication and supplies are made by the third parties outside India to the assessee and the revenue is not taxing the profits of these third parties - matter remanded back for verification of facts - AT
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