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...
Valuation - inclusion of royalty in assessable value - The running royalty is includible in the assessable value of blooms/bars cleared by the KCSSL, as the royalty is not in the nature of brand or IPR but in the nature of Techn0104' Transfer Fee for the purpose of Casting Specialty Alloy. - AT
Valuation - inclusion of royalty in assessable value - The running royalty is includible in the assessable value of blooms/bars cleared by the KCSSL, as the royalty is not in the nature of brand or IPR but in the nature of Techn0104' Transfer Fee for the purpose of Casting Specialty Alloy. - AT
Note: It is a system-generated summary and is for quick reference only.