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.271(1)(C) - paints were his “personal effects” - the plea of the assessee that receipts from sale of paintings were not offered to tax on a bona fide belief is acceptable. - as there was neither concealment of particulars of income or furnishing of inaccurate particulars of income, no penalty - AT
Penalty u/s.271(1)(C) - paints were his “personal effects” - the plea of the assessee that receipts from sale of paintings were not offered to tax on a bona fide belief is acceptable. - as there was neither concealment of particulars of income or furnishing of inaccurate particulars of income, no penalty - AT
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