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 proceedings u/s 271(1)(c) - the issue whether interest income will fall within the "Principle of Mutuality" or not itself was debatable as there were many conflicting decisions - penalty waived - AT
Penalty proceedings u/s 271(1)(c) - the issue whether interest income will fall within the "Principle of Mutuality" or not itself was debatable as there were many conflicting decisions - penalty waived - AT
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