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...
Admission of additional evidence - Merely because a document was not filed before the Assessing Officer, the same cannot be rejected on surmises and in the totality of the facts and circumstances - AT
Admission of additional evidence - Merely because a document was not filed before the Assessing Officer, the same cannot be rejected on surmises and in the totality of the facts and circumstances - AT
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