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...
Applicability of surcharge and cess on DTAA rate of tax - as per DTAA between India and Netherlands, the income tax including surcharge shall not exceed 10% - A.O. cannot charge surcharge and education cess over and above 10% of the Income Tax levied on the assessee
Applicability of surcharge and cess on DTAA rate of tax - as per DTAA between India and Netherlands, the income tax including surcharge shall not exceed 10% - A.O. cannot charge surcharge and education cess over and above 10% of the Income Tax levied on the assessee
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