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...
Intellectual property rights service - the payment made to Vemmar SRL, Itay cannot be considered as share of its profit of the joint venture - since the services are being provided outside India, recipient is liable to tax.
Intellectual property rights service - the payment made to Vemmar SRL, Itay cannot be considered as share of its profit of the joint venture - since the services are being provided outside India, recipient is liable to tax.
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