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...
Explanation 5A to section 271(1)(c) is now very clear, that if there is a difference in the original return filed under section 139 (1) of the Act and the return filed in response to section 153A of the Act, the assessee is deemed to have concealed the income - Levy of penalty confirmed - AT
Explanation 5A to section 271(1)(c) is now very clear, that if there is a difference in the original return filed under section 139 (1) of the Act and the return filed in response to section 153A of the Act, the assessee is deemed to have concealed the income - Levy of penalty confirmed - AT
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