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 u/s 40(a)(ia) - commission paid to foreign agents from India - All services are rendered abroad - When the payment made by the assessee to the overseas agent is not income chargeable to tax in India then there was no obligation on assessee to deduct TDS u/s 195 - disallowance u/s 40(a)(ia) not attracted
Disallowance u/s 40(a)(ia) - commission paid to foreign agents from India - All services are rendered abroad - When the payment made by the assessee to the overseas agent is not income chargeable to tax in India then there was no obligation on assessee to deduct TDS u/s 195 - disallowance u/s 40(a)(ia) not attracted
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