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 - rejection of transaction value - Mere presence of the CHA at the time of examination does not mean that the copy of the third chartered engineer report was provided to the respondent and it is clear that they were not given a chance to rebut the same. - AT
Valuation - rejection of transaction value - Mere presence of the CHA at the time of examination does not mean that the copy of the third chartered engineer report was provided to the respondent and it is clear that they were not given a chance to rebut the same. - AT
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