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 under Section 14A - it is mandatory for the AO to adopt the method prescribed in Rule 8D(2) - CIT(Appeals) is not justified in accepting the ad hoc expenditure on estimation of 10% of the income - AT
Disallowance under Section 14A - it is mandatory for the AO to adopt the method prescribed in Rule 8D(2) - CIT(Appeals) is not justified in accepting the ad hoc expenditure on estimation of 10% of the income - AT
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