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...
Addition u/s 40(a)(ia) - Failure to deduct TDS on expenditure debited as export charges to the Profit & Loss account - AO directed to verify the nature of payment with the C&F agreement, relevant bills of authenticated transport operators and decide the issue afresh on merits.
Addition u/s 40(a)(ia) - Failure to deduct TDS on expenditure debited as export charges to the Profit & Loss account - AO directed to verify the nature of payment with the C&F agreement, relevant bills of authenticated transport operators and decide the issue afresh on merits.
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