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 78 of FA - even if the appellant subsequently pays the amount on being pointed out by the department, along with interest, imposition of penalty under Section 78 of the Finance Act cannot be waived - penalty upheld.
Penalty u/s 78 of FA - even if the appellant subsequently pays the amount on being pointed out by the department, along with interest, imposition of penalty under Section 78 of the Finance Act cannot be waived - penalty upheld.
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