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...
Disallowance u/s 36(1)(iii) - where the recovery of principal amount was difficult the addition on account of notional interest on account of loan to said company cannot be made u/s 36(1)(iii) - no nexus between interest paid and loans made by assessee, therefore no disallowance - AT
Disallowance u/s 36(1)(iii) - where the recovery of principal amount was difficult the addition on account of notional interest on account of loan to said company cannot be made u/s 36(1)(iii) - no nexus between interest paid and loans made by assessee, therefore no disallowance - AT
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