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...
Quality of representation on behalf of the Revenue - Inconsistent stand being taken by the Revenue in different appeals raising identical issues - most matters are distributed amongst a few Advocates with the result we have occasions where a single Advocate appears in eight/nine matters a day. This indeed is expecting the moon from the panel Advocate. - HC
Quality of representation on behalf of the Revenue - Inconsistent stand being taken by the Revenue in different appeals raising identical issues - most matters are distributed amongst a few Advocates with the result we have occasions where a single Advocate appears in eight/nine matters a day. This indeed is expecting the moon from the panel Advocate. - HC
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