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...
Liability of service tax - expenditure incurred in setting up of certain branch offices in foreign countries - the legal fiction of considering a branch of an assessee as a separate establishment is not to tax a service rendered to its head office. Further, here there is no such service also has been identified with supporting evidence - the tax liability under BAS cannot be sustained. - AT
Liability of service tax - expenditure incurred in setting up of certain branch offices in foreign countries - the legal fiction of considering a branch of an assessee as a separate establishment is not to tax a service rendered to its head office. Further, here there is no such service also has been identified with supporting evidence - the tax liability under BAS cannot be sustained. - AT
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