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 - rejecting the Internal Transactional Net Margin Method (TNMM) as Most Appropriate Method (MAM) - effectively all the 12 comparables chosen by the assessee, on without prejudice basis, for applying External TNMM gets approved. - there is no scope for making any adjustment to arm’s length price even if External TNMM is adopted in the instant case. - AT
TP Adjustment - rejecting the Internal Transactional Net Margin Method (TNMM) as Most Appropriate Method (MAM) - effectively all the 12 comparables chosen by the assessee, on without prejudice basis, for applying External TNMM gets approved. - there is no scope for making any adjustment to arm’s length price even if External TNMM is adopted in the instant case. - AT
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