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...
Objections to reassessment must address material submissions relevant to the alleged source of funds for share purchases. Although the Assessing Officer's reasoning appeared prima facie sustainable on the material initially available, later material comprising a letter and annexures concerning loans and own funds also required consideration before the objections were decided. The order rejecting the objections was therefore set aside, with directions for fresh consideration after examining the additional material. The validity of the reopening was not decided, and all contentions on its merits remained open.
Objections to reassessment must address material submissions relevant to the alleged source of funds for share purchases. Although the Assessing Officer's reasoning appeared prima facie sustainable on the material initially available, later material comprising a letter and annexures concerning loans and own funds also required consideration before the objections were decided. The order rejecting the objections was therefore set aside, with directions for fresh consideration after examining the additional material. The validity of the reopening was not decided, and all contentions on its merits remained open.
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