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...
SVLDRS - Rejection of declaration - Petitioner was subjected to audit as on the relevant date - There is no challenge to the audit proceedings before us. It is not possible to give a declaration in this Petition that the audit proceedings had deemed to have lapsed on 30 June 2019 as such a declaration is outside the scope of this proceeding, even assuming that such declaration can be given. - HC
SVLDRS - Rejection of declaration - Petitioner was subjected to audit as on the relevant date - There is no challenge to the audit proceedings before us. It is not possible to give a declaration in this Petition that the audit proceedings had deemed to have lapsed on 30 June 2019 as such a declaration is outside the scope of this proceeding, even assuming that such declaration can be given. - HC
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