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...
Low net profit ratio - AO has not pointed out any defect or deficiency in the claim of expenditure nor any expenditure has been held as bogus by the AO. AO asked financial results of the last three years and proceeded to make addition in this regard without confronting the issue to the assessee which is not a justified approach. - AT
Low net profit ratio - AO has not pointed out any defect or deficiency in the claim of expenditure nor any expenditure has been held as bogus by the AO. AO asked financial results of the last three years and proceeded to make addition in this regard without confronting the issue to the assessee which is not a justified approach. - AT
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