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...
Transfer pricing adjustment rejected assessee's comparable companies in TP study analysis. Directed TPO to examine if companies are functionally comparable, apply applicable filters, and include if comparable. Rejection of comparable solely on higher turnover set aside, directed consistent turnover filter application. Deferred receivables treated as international transaction, remanded to apply bank rate after allowing 60-day credit period. Partly allowed.
Transfer pricing adjustment rejected assessee's comparable companies in TP study analysis. Directed TPO to examine if companies are functionally comparable, apply applicable filters, and include if comparable. Rejection of comparable solely on higher turnover set aside, directed consistent turnover filter application. Deferred receivables treated as international transaction, remanded to apply bank rate after allowing 60-day credit period. Partly allowed.
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