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...
Determination of residential status and place of earning the income of the company - Sikkim or Delhi (India) - place of control and management at Delhi - the business conducted/done in Sikkim - The findings of fact recorded by the AO, confirmed by the CIT(A) that the control and management of the affairs of the assessee companies was with Auditor (CA) at Delhi are based on the entire material on record. - SC
Determination of residential status and place of earning the income of the company - Sikkim or Delhi (India) - place of control and management at Delhi - the business conducted/done in Sikkim - The findings of fact recorded by the AO, confirmed by the CIT(A) that the control and management of the affairs of the assessee companies was with Auditor (CA) at Delhi are based on the entire material on record. - SC
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