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...
The action of reopening of assessment can be resorted to by the AO only if he has tangible material at his command to form a reasonable belief that income chargeable to tax had escaped assessment. Such belief of the AO cannot be substituted by that of the opinion of the audit party - HC
The action of reopening of assessment can be resorted to by the AO only if he has tangible material at his command to form a reasonable belief that income chargeable to tax had escaped assessment. Such belief of the AO cannot be substituted by that of the opinion of the audit party - HC
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