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 - share application money remained parked with AE - nothing on record to prove that transaction was sham - TPO could not have treated such transaction as a loan and charged interest thereon on notional basis.
TP Adjustment - share application money remained parked with AE - nothing on record to prove that transaction was sham - TPO could not have treated such transaction as a loan and charged interest thereon on notional basis.
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