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...
CIT(A) jurisdiction to consider the status of the appellant as an AOP - True that in the earlier years, the issue was not raised. - Merely because, it was not raised, it cannot be said that the Commissioner, has no powers to decide, if the Assessing Officer, has failed to advert to the said aspect - HC
CIT(A) jurisdiction to consider the status of the appellant as an AOP - True that in the earlier years, the issue was not raised. - Merely because, it was not raised, it cannot be said that the Commissioner, has no powers to decide, if the Assessing Officer, has failed to advert to the said aspect - HC
Note: It is a system-generated summary and is for quick reference only.