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...
Import of services - 'pouring fees' and 'signing fees' - clearly the service activity involved is not sale of space and time as contended by the appellant. What is sold is the right to advertise and promote the product of the CCIPL - Appellant provided BAS to its client CCIPL on which tax is payable - AT
Import of services - 'pouring fees' and 'signing fees' - clearly the service activity involved is not sale of space and time as contended by the appellant. What is sold is the right to advertise and promote the product of the CCIPL - Appellant provided BAS to its client CCIPL on which tax is payable - AT
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