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 194I OR 194C - External Development Charges (‘EDC’) paid to Haryana Urban Development Authority (‘HUDA’) - the Revenue does not seek to support the decision of the AO that EDC are ‘rent’ or in the nature of ‘rent’. Thus, concededly, the fundamental reasoning on which the impugned order rests is fundamentally flawed. - Petitioners in these petitions were required to deduct TDS from EDC under Section 194-I - HC
TDS u/s 194I OR 194C - External Development Charges (‘EDC’) paid to Haryana Urban Development Authority (‘HUDA’) - the Revenue does not seek to support the decision of the AO that EDC are ‘rent’ or in the nature of ‘rent’. Thus, concededly, the fundamental reasoning on which the impugned order rests is fundamentally flawed. - Petitioners in these petitions were required to deduct TDS from EDC under Section 194-I - HC
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