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...
Determination of value of assets transferred on Demerger / Succession - actual cost of the transferee company on the date of transfer is indicated in Section 43(1), explanation-6, is the written down value of the holding company.
Determination of value of assets transferred on Demerger / Succession - actual cost of the transferee company on the date of transfer is indicated in Section 43(1), explanation-6, is the written down value of the holding company.
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