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...
TDS (withholding tax) u/s 195 - Disallowance u/s 40(a)(i) - non-deduction of tax at source on payment made towards membership/subscription fee - principle of mutuality- amount paid by a member firm to the umbrella association - the payment made by the assessee to GTIL towards membership and subscription fee is not taxable at the hands of the payee. - No TDS liability - AT
TDS (withholding tax) u/s 195 - Disallowance u/s 40(a)(i) - non-deduction of tax at source on payment made towards membership/subscription fee - principle of mutuality- amount paid by a member firm to the umbrella association - the payment made by the assessee to GTIL towards membership and subscription fee is not taxable at the hands of the payee. - No TDS liability - AT
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