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...
Rectification of Mistake - Having held that penalty is not imposable, it cannot be held that penalty under Section 78 would be restricted to the extent of confirmation of demand.
Rectification of Mistake - Having held that penalty is not imposable, it cannot be held that penalty under Section 78 would be restricted to the extent of confirmation of demand.
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