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...
Treating the loan received as deemed dividend u/s 2(22)(e) - reopening of assessment - the documents produced by the assessee were cooked up and the revision of returns said to have been filed before the Registrar of Companies, was subsequent to the notice issued under Section 147; an afterthought to wriggle out of the liability.
Treating the loan received as deemed dividend u/s 2(22)(e) - reopening of assessment - the documents produced by the assessee were cooked up and the revision of returns said to have been filed before the Registrar of Companies, was subsequent to the notice issued under Section 147; an afterthought to wriggle out of the liability.
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