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...
Transfer of case u/s 147 - Deemed service of notice u/s 148 - AO never acquired jurisdiction over the assessee. Therefore, section 292BB does not come to the aid of the Department. Compliances would not bestow jurisdiction on the AO, once such jurisdiction never lay with the Assessing Officer to begin with - AT
Transfer of case u/s 147 - Deemed service of notice u/s 148 - AO never acquired jurisdiction over the assessee. Therefore, section 292BB does not come to the aid of the Department. Compliances would not bestow jurisdiction on the AO, once such jurisdiction never lay with the Assessing Officer to begin with - AT
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