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...
Deemed dividend addition u/s 2(22)(e) - Inter-Corporate Deposit (ICD) - Deposit agreement or any other bilateral agreement, which would bring out the terms and conditions and the features of the transaction as understood by the parties, it would not be appropriate to say that it is in the nature of an ICD and not a loan. - Liable to tax as deemed dividend.
Deemed dividend addition u/s 2(22)(e) - Inter-Corporate Deposit (ICD) - Deposit agreement or any other bilateral agreement, which would bring out the terms and conditions and the features of the transaction as understood by the parties, it would not be appropriate to say that it is in the nature of an ICD and not a loan. - Liable to tax as deemed dividend.
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