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 194I - non deduction of TDS - compensation paid for the use of the building / premises / place of the members for construction activities - it would be highly unjustified to treat this amount as payment of rent and to make it liable for deduction of tax at source u/s 194-I. - invoking of provisions of section 40(a)(ia) is unjustified - AT
TDS u/s 194I - non deduction of TDS - compensation paid for the use of the building / premises / place of the members for construction activities - it would be highly unjustified to treat this amount as payment of rent and to make it liable for deduction of tax at source u/s 194-I. - invoking of provisions of section 40(a)(ia) is unjustified - AT
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