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 of transfer of Goodwill- The demand raised is based on the Transfer of Business Agreement (425.25 crores) from which the value for transfer of goodwill is derived by the department on the basis of trademark license agreement - There is no domestic sale of good will annually - such a valuation for the goodwill is also without any logic or basis.
Valuation of transfer of Goodwill- The demand raised is based on the Transfer of Business Agreement (425.25 crores) from which the value for transfer of goodwill is derived by the department on the basis of trademark license agreement - There is no domestic sale of good will annually - such a valuation for the goodwill is also without any logic or basis.
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