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...
Levy of penalty u/s 271(1)(c) - defect in the notice - it was only after 10 years, when the appeals were listed for final hearing, this issue is sought to be raised - even assuming that there was defect in the notice, it had caused no prejudice to the assessee and the assessee clearly understood what was the purport and import of notice issued under Section 274 r/w.Section 271 of the Act. - HC
Levy of penalty u/s 271(1)(c) - defect in the notice - it was only after 10 years, when the appeals were listed for final hearing, this issue is sought to be raised - even assuming that there was defect in the notice, it had caused no prejudice to the assessee and the assessee clearly understood what was the purport and import of notice issued under Section 274 r/w.Section 271 of the Act. - HC
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