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 - The rejection of transaction value only on the basis of the prices circulated by the Directorate of Valuation/NIDB data, is not correct - AT
Valuation - The rejection of transaction value only on the basis of the prices circulated by the Directorate of Valuation/NIDB data, is not correct - AT
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