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 - related person or not - a proprietorship concern and a Private Limited company are not related person - even if two are held to be related, the price to any independent buyer of similar quantity only can be adopted under Rule 11 - Demand fails on both count.
Valuation - related person or not - a proprietorship concern and a Private Limited company are not related person - even if two are held to be related, the price to any independent buyer of similar quantity only can be adopted under Rule 11 - Demand fails on both count.
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