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...
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Neither the freight nor the inspection charges are paid by the appellant company for any services rendered by these company in India, and nor the payments are made to these parties in India, and therefore, by no imagination either the provisions of section 194C or section 195 are applicable - AT
Neither the freight nor the inspection charges are paid by the appellant company for any services rendered by these company in India, and nor the payments are made to these parties in India, and therefore, by no imagination either the provisions of section 194C or section 195 are applicable - AT
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