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...
Reassessment u/s 147 - reopening based on dictation/instance of the investigation wing - the authority, indicating the information was of the equal rank and not a higher authority - the AO is merely advised to take any remedial actions in accordance with the law - no instance of or at the dictate of higher authorities - reopening upheld
Reassessment u/s 147 - reopening based on dictation/instance of the investigation wing - the authority, indicating the information was of the equal rank and not a higher authority - the AO is merely advised to take any remedial actions in accordance with the law - no instance of or at the dictate of higher authorities - reopening upheld
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