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...
Bright Line Test - Whether ITAT has erred in relying upon the judgment of this Court in Sony Ericsson Mobile Communication [2015 (3) TMI 580 - DELHI HIGH COURT] as the Department has not accepted the decision passed in Sony Ericsson (supra) and has preferred an appeal against the said decision before the Supreme Court - Held No - Revenue appeal dismissed - HC
Bright Line Test - Whether ITAT has erred in relying upon the judgment of this Court in Sony Ericsson Mobile Communication [2015 (3) TMI 580 - DELHI HIGH COURT] as the Department has not accepted the decision passed in Sony Ericsson (supra) and has preferred an appeal against the said decision before the Supreme Court - Held No - Revenue appeal dismissed - HC
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