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...
Revision u/s 263 - notice issued on several points - assessee could not rebut the findings of the Ld. PCIT in respect of points ‘b’ and ‘c’ which proves that the order of the AO was erroneous and prejudicial to the interest of Revenue as the AO had failed to make any proper required enquires to frame the assessment - revision upheld
Revision u/s 263 - notice issued on several points - assessee could not rebut the findings of the Ld. PCIT in respect of points ‘b’ and ‘c’ which proves that the order of the AO was erroneous and prejudicial to the interest of Revenue as the AO had failed to make any proper required enquires to frame the assessment - revision upheld
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