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...
Export of services - providing SMS Aggregator services to facebook, Ireland - the Indian subscribers of Facebook cannot be termed as Service Recipient - In such case even the Rule 8 of POP would not apply as the service recipient i.e Facebook is situated in Ireland which is located outside India a non taxable territory. - AT
Export of services - providing SMS Aggregator services to facebook, Ireland - the Indian subscribers of Facebook cannot be termed as Service Recipient - In such case even the Rule 8 of POP would not apply as the service recipient i.e Facebook is situated in Ireland which is located outside India a non taxable territory. - AT
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