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...
Penalty proceedings u/s 271(1)(c) - The assessee herein is a technical person and may not necessarily know the complicated tax laws - assessee acting on legal advice, readily came forward and offered the capital gains without resorting to litigation - onus of bonafide is broadly discharged - No penalty.
Penalty proceedings u/s 271(1)(c) - The assessee herein is a technical person and may not necessarily know the complicated tax laws - assessee acting on legal advice, readily came forward and offered the capital gains without resorting to litigation - onus of bonafide is broadly discharged - No penalty.
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