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...
Addition under Section 41(1) - The loan transactions were on the capital account and the writing off the loan was also on capital account and did not find place in the Profit and Loss Account - Thus the cessation of the liability by itself would not lead to the attraction of Section 41(1) - HC
Addition under Section 41(1) - The loan transactions were on the capital account and the writing off the loan was also on capital account and did not find place in the Profit and Loss Account - Thus the cessation of the liability by itself would not lead to the attraction of Section 41(1) - HC
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