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...
Undervaluation - mis-declaration - there is no reference to any evidence on record to create a doubt about transaction value or to believe the certificate given by the foreign supplier - AT
Undervaluation - mis-declaration - there is no reference to any evidence on record to create a doubt about transaction value or to believe the certificate given by the foreign supplier - AT
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