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 - the two parts of Section 147 (one relating to 'such income' and the other to 'any other income') are to be read independently - addition can be made on other income even if no addition made for the such income with regard to which reasons have been recorded - HC
Reopening of assessment - the two parts of Section 147 (one relating to 'such income' and the other to 'any other income') are to be read independently - addition can be made on other income even if no addition made for the such income with regard to which reasons have been recorded - HC
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