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...
Income deemed to accrue or arise in India - fees for technical services - the assessee is making available RCITP all reports, analysis, tests, tables, plans, drawings or other documents in any form including electronic or printed form for the use of RCITP which enables RCITP to apply and use all these deliverables for its business purposes - Taxable u/A 12 of India-Singapore DTAA - AT
Income deemed to accrue or arise in India - fees for technical services - the assessee is making available RCITP all reports, analysis, tests, tables, plans, drawings or other documents in any form including electronic or printed form for the use of RCITP which enables RCITP to apply and use all these deliverables for its business purposes - Taxable u/A 12 of India-Singapore DTAA - AT
Note: It is a system-generated summary and is for quick reference only.