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...
Addition u/s. 41(1) - cessation of liability - assessee had continuously avoided the payment of tax by showing the said interest liability as payable, whereas the creditor AOP had not shown it as its ‘income’ because of the different accounting methods, that too, so managed by the assessee - additions confirmed - AT
Addition u/s. 41(1) - cessation of liability - assessee had continuously avoided the payment of tax by showing the said interest liability as payable, whereas the creditor AOP had not shown it as its ‘income’ because of the different accounting methods, that too, so managed by the assessee - additions confirmed - AT
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