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...
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There was no cross appeal filed by the Revenue before the Commissioner (Appeals). In such a scenario, we agree with the ld. Advocate that the impugned order passed by the Commissioner (Appeals) had travelled beyond the scope of the appeal before him and is required to be set aside on the said ground itself. - AT
There was no cross appeal filed by the Revenue before the Commissioner (Appeals). In such a scenario, we agree with the ld. Advocate that the impugned order passed by the Commissioner (Appeals) had travelled beyond the scope of the appeal before him and is required to be set aside on the said ground itself. - AT
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