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...
TDS u/s 194J - Audit fees - Disallowance made u/s 40(a)(ia) - non deduction of tds - the name of the payee (i.e the auditor) is very well known to the assessee in order to make provision for audit fees by crediting to the said auditor’s account - we are not inclined to accept the arguments of the ld AR that the audit report is signed after the end of the year - demand conirmed - AT
TDS u/s 194J - Audit fees - Disallowance made u/s 40(a)(ia) - non deduction of tds - the name of the payee (i.e the auditor) is very well known to the assessee in order to make provision for audit fees by crediting to the said auditor’s account - we are not inclined to accept the arguments of the ld AR that the audit report is signed after the end of the year - demand conirmed - AT
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