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 of Technical Assistance fees and project management services not claimed as expenditure but capitalized as project - capital transactions are outside the purview of TP mechanism but at time of claiming depreciation it is relevant otherwise same will be allowed only on revised value.
TP adjustment of Technical Assistance fees and project management services not claimed as expenditure but capitalized as project - capital transactions are outside the purview of TP mechanism but at time of claiming depreciation it is relevant otherwise same will be allowed only on revised value.
Note: It is a system-generated summary and is for quick reference only.