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 u/s 254 - non-consideration of decision of tribunal relied upon by the assessee on identical fact - decision subsequently approved by Hon’ble Bombay High Court and revenue’s SLP dismissed by Hon’ble Apex Court - non-consideration of binding judicial precedent of High Court would constitute mistake apparent from record
Rectification u/s 254 - non-consideration of decision of tribunal relied upon by the assessee on identical fact - decision subsequently approved by Hon’ble Bombay High Court and revenue’s SLP dismissed by Hon’ble Apex Court - non-consideration of binding judicial precedent of High Court would constitute mistake apparent from record
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