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 u/s 271(1)(c) - Though the addition is confirmed by the CIT(A), but does not show that the assessee has not recorded any transaction in his books of account or any transaction recorded by him is false - Addition on account of gross profit was purely on estimation basis - No penalty
Penalty u/s 271(1)(c) - Though the addition is confirmed by the CIT(A), but does not show that the assessee has not recorded any transaction in his books of account or any transaction recorded by him is false - Addition on account of gross profit was purely on estimation basis - No penalty
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