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...
Addition u/s 68 - share capital and share premium - no enquiries were conducted by the ld AO u/s 133(6) and/or 131 from the share subscribers - the assessee by producing necessary documents viz. detailed chart of inflow and outflow of funds, IT records, audited Balance Sheets, bank statement copy etc of self and all other parties involved - sufficiently established the identity and creditworthiness of the share subscribers and the genuineness of the share transaction - no addition
Addition u/s 68 - share capital and share premium - no enquiries were conducted by the ld AO u/s 133(6) and/or 131 from the share subscribers - the assessee by producing necessary documents viz. detailed chart of inflow and outflow of funds, IT records, audited Balance Sheets, bank statement copy etc of self and all other parties involved - sufficiently established the identity and creditworthiness of the share subscribers and the genuineness of the share transaction - no addition
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