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...
A genuine donation made by cheque to an approved institution remained substantively eligible for deduction, and the claim could not be refused merely because the wrong deduction provision was quoted. The Tribunal held that a technical misdescription of the provision did not defeat relief where the facts already on record established eligibility and allowing the claim under the correct provision caused no adverse effect on total income. It also recognised that appellate authority could grant the proper relief on the existing material, so the disallowance was unsustainable and was directed to be deleted.
A genuine donation made by cheque to an approved institution remained substantively eligible for deduction, and the claim could not be refused merely because the wrong deduction provision was quoted. The Tribunal held that a technical misdescription of the provision did not defeat relief where the facts already on record established eligibility and allowing the claim under the correct provision caused no adverse effect on total income. It also recognised that appellate authority could grant the proper relief on the existing material, so the disallowance was unsustainable and was directed to be deleted.
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