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...
Validity of notice issued for re-assessment - satisfaction of requirement of section 151(2) before issuance of notice u/s 148 - it was a fit case for issuance of notice u/s 148 - Merely because the papers were thereafter for some erroneous reason also placed before the Commissioner who also recorded his similar satisfaction would not take away anything from the previous conclusion. - HC
Validity of notice issued for re-assessment - satisfaction of requirement of section 151(2) before issuance of notice u/s 148 - it was a fit case for issuance of notice u/s 148 - Merely because the papers were thereafter for some erroneous reason also placed before the Commissioner who also recorded his similar satisfaction would not take away anything from the previous conclusion. - HC
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