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...
Valuation - inclusison of re-imbursment of expenses - pure agency services - Rule 5(1) of the valuation Rules - From a perusal of the activity undertaken by the appellant, it is seen that the appellant had only paid the amount / charges on behalf of their clients to respective service providers and their clients reimbursed the charges to the appellant. The said transactions of appellant do not fall under ‘Support Service of Business or commerce’. - AT
Valuation - inclusison of re-imbursment of expenses - pure agency services - Rule 5(1) of the valuation Rules - From a perusal of the activity undertaken by the appellant, it is seen that the appellant had only paid the amount / charges on behalf of their clients to respective service providers and their clients reimbursed the charges to the appellant. The said transactions of appellant do not fall under ‘Support Service of Business or commerce’. - AT
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