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 - “unascertained liability” had been claimed and allowed as expenditure - the assumption drawn by the AO in the “reasons to believe” is farfetched, vague and a mere pretence - HC
Reopening of assessment u/s 147 - “unascertained liability” had been claimed and allowed as expenditure - the assumption drawn by the AO in the “reasons to believe” is farfetched, vague and a mere pretence - HC
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