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 195 on payment of secondment cost - The assessee has reimbursed the salary cost of seconded employees on cost-to-cost basis without any profit element. The assessee has duly deducted tax at source from these payments u/s 192 - The stated employees have worked under the supervision and control of the assessee. - No further requirement of deduction of TDS u/s 195 - AT
TDS u/s 195 on payment of secondment cost - The assessee has reimbursed the salary cost of seconded employees on cost-to-cost basis without any profit element. The assessee has duly deducted tax at source from these payments u/s 192 - The stated employees have worked under the supervision and control of the assessee. - No further requirement of deduction of TDS u/s 195 - AT
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