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...
Business Auxiliary Services - export of services or not - Marketing operations done by an assessee in India cannot be said to be at behest of any Indian customers - the services were held to be as having been delivered and/or used outside India and thus being export of services. - AT
Business Auxiliary Services - export of services or not - Marketing operations done by an assessee in India cannot be said to be at behest of any Indian customers - the services were held to be as having been delivered and/or used outside India and thus being export of services. - AT
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