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...
Addition of deemed dividend under Section 2(22)(e) - quantum of accumulated profits - inclusion of share premium - The share premium account cannot partake the nature of commercial profit and, therefore, it cannot be called as accumulated profits - AT
Addition of deemed dividend under Section 2(22)(e) - quantum of accumulated profits - inclusion of share premium - The share premium account cannot partake the nature of commercial profit and, therefore, it cannot be called as accumulated profits - AT
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