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...
Penalty for belated filing of TDS returns may not be sustained where penalty proceedings are initiated after an unexplained nine-year lapse. The Tribunal note states that, following a coordinate Bench decision on materially similar facts, the delayed penalty was treated as illegal and unsustainable. The penalty order was set aside and the taxpayer's appeal was allowed.
Penalty for belated filing of TDS returns may not be sustained where penalty proceedings are initiated after an unexplained nine-year lapse. The Tribunal note states that, following a coordinate Bench decision on materially similar facts, the delayed penalty was treated as illegal and unsustainable. The penalty order was set aside and the taxpayer's appeal was allowed.
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