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...
Levy of Service Tax - Intellectual Property Service - permission granted to the CBUs / TMUs to affix the brand name / trade name belonging to them on the IMFL manufactured - The ultimate beneficiary of the technical know-how are the intellectual property if any for that matter is the appellant themselves and therefore, it is incorrect to say that there is any transfer of temporary leasing of intellectual property. Therefore, the entire case of the Department is based on a false surmise. - AT
Levy of Service Tax - Intellectual Property Service - permission granted to the CBUs / TMUs to affix the brand name / trade name belonging to them on the IMFL manufactured - The ultimate beneficiary of the technical know-how are the intellectual property if any for that matter is the appellant themselves and therefore, it is incorrect to say that there is any transfer of temporary leasing of intellectual property. Therefore, the entire case of the Department is based on a false surmise. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4823 
Join Channel 
