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 addition - Specified Domestic Transaction (SDT) of Rent payment - Once it is held that the property was used by the assessee for its business purpose and the Revenue brought no contrary reliable evidence on record, the case of the TPO applying `Other method’ and determining Nil ALP on the ground that no independent party would have paid any rent for not having occupied the premises, fails. - AT
TP addition - Specified Domestic Transaction (SDT) of Rent payment - Once it is held that the property was used by the assessee for its business purpose and the Revenue brought no contrary reliable evidence on record, the case of the TPO applying `Other method’ and determining Nil ALP on the ground that no independent party would have paid any rent for not having occupied the premises, fails. - AT
Note: It is a system-generated summary and is for quick reference only.