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...
Nature of activity - manufacture or service - making of photo books/albums, calendars, brochures etc. to their different customers - The Tribunal concurred with the assessee's contention that their activity constitutes 'manufacture' rather than a taxable service. They noted that the process undertaken by the assessee involves significant transformation and results in the creation of new commercial products.
Nature of activity - manufacture or service - making of photo books/albums, calendars, brochures etc. to their different customers - The Tribunal concurred with the assessee's contention that their activity constitutes 'manufacture' rather than a taxable service. They noted that the process undertaken by the assessee involves significant transformation and results in the creation of new commercial products.
Note: It is a system-generated summary and is for quick reference only.