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 presumption u/s 292C of the Act is rebuttable presumption and does not lead to a conclusive evidence. The assessee from the very beginning denied that the documents belonged to him and the AO made no effort to find out the real truth - No additions - AT
The presumption u/s 292C of the Act is rebuttable presumption and does not lead to a conclusive evidence. The assessee from the very beginning denied that the documents belonged to him and the AO made no effort to find out the real truth - No additions - AT
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