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...
The question of a reverse levy of tax on the recipient of the service under section 66A of the Finance Act, 1994 would arise only if the service itself is taxable and, in the absence of any reason to subject the said royalty to tax, the demand under section 66A would not survive.
The question of a reverse levy of tax on the recipient of the service under section 66A of the Finance Act, 1994 would arise only if the service itself is taxable and, in the absence of any reason to subject the said royalty to tax, the demand under section 66A would not survive.
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