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...
Deemed dividend u/s 2(22)(e) - nature of receipt of sum from a company in which assessee is having 25.24% holding - assessee’s case that the same formed part of transactions in mutual or current account - assessee claimed that it was not loan or advance - the contention of the assessee accepted.
Deemed dividend u/s 2(22)(e) - nature of receipt of sum from a company in which assessee is having 25.24% holding - assessee’s case that the same formed part of transactions in mutual or current account - assessee claimed that it was not loan or advance - the contention of the assessee accepted.
Note: It is a system-generated summary and is for quick reference only.