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...
Disallowance of excessive licence fee paid to M/s Uflex Ltd. - increase of the license fee from ₹ 50 Lac per month to ₹ 2 Crore per month - the issue of increasing the license fee is considered by all the authorities in the preceding years therefore, in the immediately preceding year, we hold that the CIT(A) was fully justified in allowing the license fee.
Disallowance of excessive licence fee paid to M/s Uflex Ltd. - increase of the license fee from ₹ 50 Lac per month to ₹ 2 Crore per month - the issue of increasing the license fee is considered by all the authorities in the preceding years therefore, in the immediately preceding year, we hold that the CIT(A) was fully justified in allowing the license fee.
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