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 - includibility - royalty paid to copyright-holders of films - The appellant is not wrong in contending that there is no proper finding on relationship with the foreign supplier and the consequent rejection of declared value on that ground will not meet the test of law
Valuation - includibility - royalty paid to copyright-holders of films - The appellant is not wrong in contending that there is no proper finding on relationship with the foreign supplier and the consequent rejection of declared value on that ground will not meet the test of law
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