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...
TDS u/s 195 - assessee purchased software from two nonresidents companies - Purchase of software is not in the nature of Royalty and no disallowance u/s.40(a)(i) of the Act is warranted. - AT
TDS u/s 195 - assessee purchased software from two nonresidents companies - Purchase of software is not in the nature of Royalty and no disallowance u/s.40(a)(i) of the Act is warranted. - AT
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