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 interest on free loan - The cost of the bank guarantee is incurred by the appellant - Thus, there is no case to add an amount of notional interest in the value of taxable services rendered.
Valuation - inclusion of interest on free loan - The cost of the bank guarantee is incurred by the appellant - Thus, there is no case to add an amount of notional interest in the value of taxable services rendered.
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