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...
Appellate authorities power to consider the claim not made in the return - assessee is entitled to raise not merely additional legal submissions, before the appellate authorities, but also entitled to raise additional claim before them and further appellate authorities have discretion to permit such additional claims. - AT
Appellate authorities power to consider the claim not made in the return - assessee is entitled to raise not merely additional legal submissions, before the appellate authorities, but also entitled to raise additional claim before them and further appellate authorities have discretion to permit such additional claims. - AT
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