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...
Penalty u/s 271(1)(c) - income from other sources - as per assessee reimbursements do not constitute the income of the assessee - the agreement constitutes ‘self-serving document’ - levy of penalty confirmed - AT
Penalty u/s 271(1)(c) - income from other sources - as per assessee reimbursements do not constitute the income of the assessee - the agreement constitutes ‘self-serving document’ - levy of penalty confirmed - AT
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