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...
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Default in furnishing TCS statements - statement submitted u/s 200(3) are to be processed u/s 200A and then AO can levy fine u/s 234E - once a procedure has been provided by the legislature, then it does not give discretion to the AO to levy fine without processing the statements - Merely mentioning S. 234E would not become an order u/s 234E in isolation - appeal maintainable
Default in furnishing TCS statements - statement submitted u/s 200(3) are to be processed u/s 200A and then AO can levy fine u/s 234E - once a procedure has been provided by the legislature, then it does not give discretion to the AO to levy fine without processing the statements - Merely mentioning S. 234E would not become an order u/s 234E in isolation - appeal maintainable
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