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...
Invocation of extended period of limitation - relevant date u/s 11A - date of knowledge or the date of discovery of the fraud by the Revenue is neither determinative nor decisive - Tribunal's order is ex-facie erroneous and unsustainable in law. It is vitiated by complete non application of mind as well - HC
Invocation of extended period of limitation - relevant date u/s 11A - date of knowledge or the date of discovery of the fraud by the Revenue is neither determinative nor decisive - Tribunal's order is ex-facie erroneous and unsustainable in law. It is vitiated by complete non application of mind as well - HC
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