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...
Addition u/s 56(2)(viib) - shares being issued at excessive rate - When shares are issued at a premium by a subsidiary to its holding company, based on a recognized valuation method like the Discounted Cash Flow, additions under Section 56(2)(viib) are not justified unless there is evidence of unaccounted money or manipulation. - AT
Addition u/s 56(2)(viib) - shares being issued at excessive rate - When shares are issued at a premium by a subsidiary to its holding company, based on a recognized valuation method like the Discounted Cash Flow, additions under Section 56(2)(viib) are not justified unless there is evidence of unaccounted money or manipulation. - AT
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