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...
Disallowance of expenses when the business was not fully functional - - Nowhere in the order of the AO there is a whisper as to how the expenditure is excessive and how the expenditure is not having been incurred for the purpose of business u/s 37(1) or there is a personal expenditure - AO cannot disallow expenditure on estimate basis - AT
Disallowance of expenses when the business was not fully functional - - Nowhere in the order of the AO there is a whisper as to how the expenditure is excessive and how the expenditure is not having been incurred for the purpose of business u/s 37(1) or there is a personal expenditure - AO cannot disallow expenditure on estimate basis - AT
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