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...
Disallowance u/s 14A(2) r.w.r. 8D(2)(ii) - expenditure will have to be excluded from the expenses to be allocated under rule 8D(2)(ii) - entire transaction of borrowing and landing is completely a back to back transaction - Just because it is routed through the same bank account, it cannot be presumed that the money is out of the common funds - AT
Disallowance u/s 14A(2) r.w.r. 8D(2)(ii) - expenditure will have to be excluded from the expenses to be allocated under rule 8D(2)(ii) - entire transaction of borrowing and landing is completely a back to back transaction - Just because it is routed through the same bank account, it cannot be presumed that the money is out of the common funds - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
