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 271(1)(c) on addition of rental income - the assessment proceedings and penalty proceedings are quite distinct and the findings given in the assessment order are not conclusive. Accordingly, mere addition of amount as income is not the criteria to levy penalty. - AT
Penalty under section 271(1)(c) on addition of rental income - the assessment proceedings and penalty proceedings are quite distinct and the findings given in the assessment order are not conclusive. Accordingly, mere addition of amount as income is not the criteria to levy penalty. - AT
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