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...
Penalty under Section 271D - violation of provisions of Section 269SS - the funds were urgently required for conversion of the property, a loan was taken from the Samajwadi Party, which was deposited in her account and, subsequently, the loan was paid back to the Samajwadi Party - as the genuineness of the transaction has not been disputed by the AO - No penalty - HC
Penalty under Section 271D - violation of provisions of Section 269SS - the funds were urgently required for conversion of the property, a loan was taken from the Samajwadi Party, which was deposited in her account and, subsequently, the loan was paid back to the Samajwadi Party - as the genuineness of the transaction has not been disputed by the AO - No penalty - HC
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