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...
TDS u/s 195 - Royalty and FTS payment for non deduction of TDS - Co-location services and connectivity services provided for the process of connecting by the assessee with the various customers towards making voice and data connectivity - the consideration being for the use and the right to use of the process, it is 'royalty' within the meaning of Clause (iii) of Explanation 2 to Section 9(1)(vi) of the Income Tax Act - AT
TDS u/s 195 - Royalty and FTS payment for non deduction of TDS - Co-location services and connectivity services provided for the process of connecting by the assessee with the various customers towards making voice and data connectivity - the consideration being for the use and the right to use of the process, it is 'royalty' within the meaning of Clause (iii) of Explanation 2 to Section 9(1)(vi) of the Income Tax Act - AT
Note: It is a system-generated summary and is for quick reference only.