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...
Tds U/S 195 - Grant of license - The amount paid by the appellant to NPL is not in the nature of royalty within the meaning of the DTAA between India - Admittedly NPL did not have a PE in India - there was no obligation on the part of the appellant to deduct tax at source u/s.195 - AT
Tds U/S 195 - Grant of license - The amount paid by the appellant to NPL is not in the nature of royalty within the meaning of the DTAA between India - Admittedly NPL did not have a PE in India - there was no obligation on the part of the appellant to deduct tax at source u/s.195 - AT
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