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 of expenditure of “Additional discount/rate difference” - appellant has not furnished any evidence to support its claim - Since the payments were withheld the assessee could have claimed as a bad debt, which was not done - No allowance - AT
Disallowance of expenditure of “Additional discount/rate difference” - appellant has not furnished any evidence to support its claim - Since the payments were withheld the assessee could have claimed as a bad debt, which was not done - No allowance - AT
Note: It is a system-generated summary and is for quick reference only.