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 typographical error in the appellate directions led the Assessing Officer to retain part of a section 69 addition for unexplained investment, even though the draft assessment order had made a combined addition for time deposits and reportable transactions. The Tribunal read the reasoning in the directions as showing that both underlying components were meant to be deleted, and treated the differing aggregate figure as a clerical mistake. On that basis, no balance addition could survive in the final assessment order, and the retained amount was deleted.
A typographical error in the appellate directions led the Assessing Officer to retain part of a section 69 addition for unexplained investment, even though the draft assessment order had made a combined addition for time deposits and reportable transactions. The Tribunal read the reasoning in the directions as showing that both underlying components were meant to be deleted, and treated the differing aggregate figure as a clerical mistake. On that basis, no balance addition could survive in the final assessment order, and the retained amount was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4788
Join Channel
TaxTMI 
