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...
Income accrued in India - FTS - No PE in India - DTAA between India and UAE - As per DTAA, there is no specific clause in respect of FTS and same has to be considered as business profit in the absence of such clause and permanent establishment in India.
Income accrued in India - FTS - No PE in India - DTAA between India and UAE - As per DTAA, there is no specific clause in respect of FTS and same has to be considered as business profit in the absence of such clause and permanent establishment in India.
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