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...
Recording of wrong facts & reasoning by Tribunal - Tribunal did not correctly appreciate as to what AO and CIT (A) held and what was their reasoning which led to their respective conclusion - Tribunal being the last Court of appeal on facts, its finding on the question of fact is of significance - case remanded to tribunal
Recording of wrong facts & reasoning by Tribunal - Tribunal did not correctly appreciate as to what AO and CIT (A) held and what was their reasoning which led to their respective conclusion - Tribunal being the last Court of appeal on facts, its finding on the question of fact is of significance - case remanded to tribunal
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