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...
Levy of penalty u/s 271D – it is not legally correct to contend that the assessee and its members are one and the same person and the transactions with the members are outside the scope of s. 269SS - AT
Levy of penalty u/s 271D – it is not legally correct to contend that the assessee and its members are one and the same person and the transactions with the members are outside the scope of s. 269SS - AT
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