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...
Addition u/s 69 - unless it is first established beyond doubt that there is an investment which is not recorded by the Assessee in its books, no occasion to explain about the nature and source of the investment can arise - The invocation of Section 69 of the Act before establishing investment not recorded in its books of Account, is not justified - HC
Addition u/s 69 - unless it is first established beyond doubt that there is an investment which is not recorded by the Assessee in its books, no occasion to explain about the nature and source of the investment can arise - The invocation of Section 69 of the Act before establishing investment not recorded in its books of Account, is not justified - HC
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