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...
TP adjustment - without factoring in the difference in FAR, the comparison done by the TPO is not sustainable - there is no proper reason to apply CUP method, instead of that consistently applied earlier method of TNMM, as the most appropriate method (MAM).
TP adjustment - without factoring in the difference in FAR, the comparison done by the TPO is not sustainable - there is no proper reason to apply CUP method, instead of that consistently applied earlier method of TNMM, as the most appropriate method (MAM).
Note: It is a system-generated summary and is for quick reference only.