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.271BA - no affidavit from the Director or by Chartered Accountant to show that report in Form No.3CEB was obtained before the due date of filing of the return or the said Audit report was made available to the AO either before processing the return u/s.143(1) or completion of assessment order u/s.143(3) of the Act - penalty confirmed - AT
Penalty u/s.271BA - no affidavit from the Director or by Chartered Accountant to show that report in Form No.3CEB was obtained before the due date of filing of the return or the said Audit report was made available to the AO either before processing the return u/s.143(1) or completion of assessment order u/s.143(3) of the Act - penalty confirmed - AT
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