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 u/s 271(1)(c) - Previous approval of DCIT - The restrictions placed 271(1)(iii) cannot be interpreted in a manner to curtail the jurisdiction on the ITO, not to initiate proceedings - HC
Penalty u/s 271(1)(c) - Previous approval of DCIT - The restrictions placed 271(1)(iii) cannot be interpreted in a manner to curtail the jurisdiction on the ITO, not to initiate proceedings - HC
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