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 to payment of interest on ECB loan - TPO himself has stated that while granting permission to the assessee for availing ECB loan, the RBI has fixed the interest rate at six months USD LIBOR plus 350 basis points - directed to determined interest rate at six months USD LIBOR rate plus 300 basis points
TP adjustment to payment of interest on ECB loan - TPO himself has stated that while granting permission to the assessee for availing ECB loan, the RBI has fixed the interest rate at six months USD LIBOR plus 350 basis points - directed to determined interest rate at six months USD LIBOR rate plus 300 basis points
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