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 u/s 271C - non deduction of tax at source u/s 194A - the case of the assessee squarely falls under the provisions of Section 273B and penalty is not leviable because assessee is able to prove that there was a reasonable cause for the said failure - AT
Penalty u/s 271C - non deduction of tax at source u/s 194A - the case of the assessee squarely falls under the provisions of Section 273B and penalty is not leviable because assessee is able to prove that there was a reasonable cause for the said failure - AT
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