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...
Addition made u/s 40A(3) - payment through bearer cheques - payment made otherwise than by cheque or crossed cheque - since the entries in the bank statement reflects the names of two parties and also because of compelling circumstances of the sellers asking for such payment, then we hold that there is no merit in invoking provisions of section 40A(3) to such transactions - AT
Addition made u/s 40A(3) - payment through bearer cheques - payment made otherwise than by cheque or crossed cheque - since the entries in the bank statement reflects the names of two parties and also because of compelling circumstances of the sellers asking for such payment, then we hold that there is no merit in invoking provisions of section 40A(3) to such transactions - AT
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