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...
Eligible assessee u/s 144C - Since the assessee is a non-resident partnership firm, it cannot be characterized as an Indian company - As the assessee is not an ‘eligible assessee’, the assessment should have been completed u/s 143(3) instead of adopting the path of passing the draft assessment order u/s 144C(1). - AT
Eligible assessee u/s 144C - Since the assessee is a non-resident partnership firm, it cannot be characterized as an Indian company - As the assessee is not an ‘eligible assessee’, the assessment should have been completed u/s 143(3) instead of adopting the path of passing the draft assessment order u/s 144C(1). - AT
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