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...
In the context of section 80-O, the services may be rendered from India, but have to be performed on foreign soil. Any other interpretation renders the Explanation (iii), in our view, otiose. - HC
In the context of section 80-O, the services may be rendered from India, but have to be performed on foreign soil. Any other interpretation renders the Explanation (iii), in our view, otiose. - HC
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