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 - product development cost - includibility - The appellant made attempt to be enriched at the cost of Revenue. For deliberate act of the appellant to exclude the debit note amount from the scope of duty, questionable conduct and oblique motive of the appellant came up and that contributed to its implication to the charge
Valuation - product development cost - includibility - The appellant made attempt to be enriched at the cost of Revenue. For deliberate act of the appellant to exclude the debit note amount from the scope of duty, questionable conduct and oblique motive of the appellant came up and that contributed to its implication to the charge
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