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 - Rejection of transaction value at the time of reviewing order - Since, NIDB data is not a mandatory requisite under the Rules, the same cannot be held to be a cogent evidence proving the reasonable doubt of the assessing officer.
Valuation - related person - Rejection of transaction value at the time of reviewing order - Since, NIDB data is not a mandatory requisite under the Rules, the same cannot be held to be a cogent evidence proving the reasonable doubt of the assessing officer.
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