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...
Reopening of assessment u/s 147 - There has to be some tangible material on the basis of which a reason to belief can be formed that some income had escaped assessment - the AO has failed to prove any escapement of income - HC
Reopening of assessment u/s 147 - There has to be some tangible material on the basis of which a reason to belief can be formed that some income had escaped assessment - the AO has failed to prove any escapement of income - HC
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