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 - selection of MAM - Tribunal held that resale price method adopted by the assessee in determining its ALP of international transactions with AE, is not applicable, while remanding the matter back to the TPO for fresh determination - Transfer Pricing Officer is directed to redo the entire process of determination of ALP of international transactions with AE, without being influenced by any observation made by the Tribunal and render an independent finding with regard to the issues involved herein - HC
TP Adjustment - selection of MAM - Tribunal held that resale price method adopted by the assessee in determining its ALP of international transactions with AE, is not applicable, while remanding the matter back to the TPO for fresh determination - Transfer Pricing Officer is directed to redo the entire process of determination of ALP of international transactions with AE, without being influenced by any observation made by the Tribunal and render an independent finding with regard to the issues involved herein - HC
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