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) - addition sustain on Bogus purchases - When it is not discernible from the assessment order as to whether assessee has furnished inaccurate particulars of income or has concealed particulars of income so as to apply the deeming provisions contained under Explanation1 (A) & 1(B) of the Act, the penalty u/s 271(1)(c) of the Act is not sustainable.
Penalty u/s 271(1)(C) - addition sustain on Bogus purchases - When it is not discernible from the assessment order as to whether assessee has furnished inaccurate particulars of income or has concealed particulars of income so as to apply the deeming provisions contained under Explanation1 (A) & 1(B) of the Act, the penalty u/s 271(1)(c) of the Act is not sustainable.
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