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...
Failure to provide opportunity of being heard – Addition made in the hands of firm – no material had been produced to show that partners had independent source of income - additions confirmed - HC
Failure to provide opportunity of being heard – Addition made in the hands of firm – no material had been produced to show that partners had independent source of income - additions confirmed - HC
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