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...
Levy of penalty - the assesse's stand that they were under a bonafide belief that no tax liability would fall upon them as the same stands discharged by the sub-contractor is required to be appreciated in which case, the provisions of section 80 of the Finance Act, 1994 would get invoked – no penalty - AT
Levy of penalty - the assesse's stand that they were under a bonafide belief that no tax liability would fall upon them as the same stands discharged by the sub-contractor is required to be appreciated in which case, the provisions of section 80 of the Finance Act, 1994 would get invoked – no penalty - AT
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