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...
TDS u/s 195 - fees for technical services u/s 9 (1) (vii) - Assuming that Licensor, rendered services as defined u/s. 9(l)(vii) Explanation 2 of the Act, yet it does not satisfy tire requirement of technical services as contained in India-UK DTAA.
TDS u/s 195 - fees for technical services u/s 9 (1) (vii) - Assuming that Licensor, rendered services as defined u/s. 9(l)(vii) Explanation 2 of the Act, yet it does not satisfy tire requirement of technical services as contained in India-UK DTAA.
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