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 194A - processing charges (upfront fee) paid for taking loan from bank - Since, the assessee could not justify the payments without deduction of tax with necessary evidence and also fails to obtain the certificate from the Auditor to the effect what was quantified under relevant Form No.3CD, includes processing fees paid to banks of which provisions of Section 194A has no application. - AT
TDS u/s 194A - processing charges (upfront fee) paid for taking loan from bank - Since, the assessee could not justify the payments without deduction of tax with necessary evidence and also fails to obtain the certificate from the Auditor to the effect what was quantified under relevant Form No.3CD, includes processing fees paid to banks of which provisions of Section 194A has no application. - AT
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