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...
Disallowance u/s 36[1](viii] - no reserve was created - appellant submits that the appellant may be permitted now to create such reserve - such non-creation of special reserve by the assessee cannot be made good by creating any reserve on a later date - AT
Disallowance u/s 36[1](viii] - no reserve was created - appellant submits that the appellant may be permitted now to create such reserve - such non-creation of special reserve by the assessee cannot be made good by creating any reserve on a later date - AT
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