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...
Valuation - arbitrary enhancement of the value of import goods - 100% EOU - There is no case that the respondent has paid any extra consideration to the foreign supplier. The department has also not made out a case that any contemporaneous import exists - No demand can be made - AT
Valuation - arbitrary enhancement of the value of import goods - 100% EOU - There is no case that the respondent has paid any extra consideration to the foreign supplier. The department has also not made out a case that any contemporaneous import exists - No demand can be made - AT
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