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 - loading the assessable value on the basis of other brand of goods - There is no evidence on record that both these brands of Chinese origin are similar - loading the assessable value on the basis of other brand of goods not justified - AT
Valuation - loading the assessable value on the basis of other brand of goods - There is no evidence on record that both these brands of Chinese origin are similar - loading the assessable value on the basis of other brand of goods not justified - AT
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