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...
Refund - Excess interest deposited – interest calculated at higher rate - excess interest paid was an arithmetic error and need to be rectified. Revenue not allowed to retain the excess amount - refund allowed - AT
Refund - Excess interest deposited – interest calculated at higher rate - excess interest paid was an arithmetic error and need to be rectified. Revenue not allowed to retain the excess amount - refund allowed - AT
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