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...
Rejection of the claim of inter-state purchases on commission basis - issuance of Form-H - Though it is true that a claim of the export sale cannot co-exist with the claim of interstate purchase of wheat on commission basis, both claims arising in the hands of the same assessee, however, it is to be seen whether the nature of transaction performed by the parties would get altered or determined solely upon issuance of Form- H
Rejection of the claim of inter-state purchases on commission basis - issuance of Form-H - Though it is true that a claim of the export sale cannot co-exist with the claim of interstate purchase of wheat on commission basis, both claims arising in the hands of the same assessee, however, it is to be seen whether the nature of transaction performed by the parties would get altered or determined solely upon issuance of Form- H
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