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 - in the earlier years same issue had been sent back to the A.O. for verification and adjudication in the light of the findings of the Hon'ble High Court - since CIT(A) himself made verification in accordance with the findings of the Hon'ble High Court in presnt appeal, ITAT dismissed the appeal of revenue - no error in the order of the I.T.A.T.
Rectification u/s 254 - in the earlier years same issue had been sent back to the A.O. for verification and adjudication in the light of the findings of the Hon'ble High Court - since CIT(A) himself made verification in accordance with the findings of the Hon'ble High Court in presnt appeal, ITAT dismissed the appeal of revenue - no error in the order of the I.T.A.T.
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