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...
Non-compete fees receipt - taxability under Section 17(3)(iii) or 28(va) as salary income or business income or not - profit in lieu of salary - assessee is an individual and was Financial Director - it cannot be inferred that the said agreement in any way intended to compensate the assessee for loss of employment or in lieu of salary - amount is not taxable - AT
Non-compete fees receipt - taxability under Section 17(3)(iii) or 28(va) as salary income or business income or not - profit in lieu of salary - assessee is an individual and was Financial Director - it cannot be inferred that the said agreement in any way intended to compensate the assessee for loss of employment or in lieu of salary - amount is not taxable - AT
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