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...
Distribution of capital assets u/s 45(4) - partnership firm - crediting revaluation surplus to partners account settling their accounts on their retirement - It is the retiring partners who have been benefitted by receiving much more than actual capital contributed by them on account of revaluation. Thus there can be no case of tax avoidance by colorable device by the firm - AT
Distribution of capital assets u/s 45(4) - partnership firm - crediting revaluation surplus to partners account settling their accounts on their retirement - It is the retiring partners who have been benefitted by receiving much more than actual capital contributed by them on account of revaluation. Thus there can be no case of tax avoidance by colorable device by the firm - AT
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