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...
IPR service - Merely because the payment for that transfer continued even during the period when that services became liable to tax does not negate the fact that the taxable event was the transfer of rights which took place during the time when the service was non-taxable - stay granted - AT
IPR service - Merely because the payment for that transfer continued even during the period when that services became liable to tax does not negate the fact that the taxable event was the transfer of rights which took place during the time when the service was non-taxable - stay granted - AT
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