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...
Deduction of tax at source u/s. 195 - it is proved that assessee is merely a trader of software products of the foreign company - payment made is not in the nature of 'royalty'. - AT
Deduction of tax at source u/s. 195 - it is proved that assessee is merely a trader of software products of the foreign company - payment made is not in the nature of 'royalty'. - AT
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