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...
Validity of assessment completed u/s 144 - absence of notice - Since the notices were not received back “unserved” within thirty days of its issuance, there would be presumption under the law that notice had been duly served upon the assessee. The assessee received the Show Cause Notice u/s. 271(1)(b) dated 18.06.2008. Thus, the Assessment order u/s 144 is proper. - AT
Validity of assessment completed u/s 144 - absence of notice - Since the notices were not received back “unserved” within thirty days of its issuance, there would be presumption under the law that notice had been duly served upon the assessee. The assessee received the Show Cause Notice u/s. 271(1)(b) dated 18.06.2008. Thus, the Assessment order u/s 144 is proper. - AT
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