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 - ALP of interest on receivables - no credit period was agreed between the parties - TPO should not calculate the collection period selectively which are beyond 90 days, he has to calculate the average of collection for the year under consideration of all the transactions - the adjustment only to the extent it crossed 90 days
TP Adjustment - ALP of interest on receivables - no credit period was agreed between the parties - TPO should not calculate the collection period selectively which are beyond 90 days, he has to calculate the average of collection for the year under consideration of all the transactions - the adjustment only to the extent it crossed 90 days
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
