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...
Non-compliance of the provisions of section 40(a)(i) - commission payments received by the Indian agent on behalf of the Hong Kong entity in India - Non deduction of TDS - The inevitable conclusion in law is that the commission payments are liable to tax in India - Additions confirmed - HC
Non-compliance of the provisions of section 40(a)(i) - commission payments received by the Indian agent on behalf of the Hong Kong entity in India - Non deduction of TDS - The inevitable conclusion in law is that the commission payments are liable to tax in India - Additions confirmed - HC
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