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...
Disallowance on account of expenses incurred through sub-contractors - bogus expenditure - these companies are merely paper companies, having complied with proper paper work, but not possessing necessary expertise to render technical services to the assessee - Even if TDS was deducted, expenditure cannot be allowed. - AT
Disallowance on account of expenses incurred through sub-contractors - bogus expenditure - these companies are merely paper companies, having complied with proper paper work, but not possessing necessary expertise to render technical services to the assessee - Even if TDS was deducted, expenditure cannot be allowed. - AT
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