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 194J and u/s 195 - payment by way of reimbursement to member companies, allowances paid to resident and non-resident personnel and payment to foreign agents - reimbursement of Indian Salary and benefits - Member employer company deducts tax at source under section 192 of the Act from the Indian salary of such employee as they continue to get their salary from his employer member companies. - CIT(A) rightly held that assessee not in default u/s 201(1) - AT
TDS - u/s 194J and u/s 195 - payment by way of reimbursement to member companies, allowances paid to resident and non-resident personnel and payment to foreign agents - reimbursement of Indian Salary and benefits - Member employer company deducts tax at source under section 192 of the Act from the Indian salary of such employee as they continue to get their salary from his employer member companies. - CIT(A) rightly held that assessee not in default u/s 201(1) - AT
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