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 - proceedings after expiry of 6 years - direction by court or mere observation - AO applied the provisions of section 150, when the findings of the coordinate bench are not direction but observation - proceedings initiated u/s 147 beyond 6 years are void ab-initio as per the time limit prescribed u/s 149 - assessment order quashed
Reassessment u/s 147 - proceedings after expiry of 6 years - direction by court or mere observation - AO applied the provisions of section 150, when the findings of the coordinate bench are not direction but observation - proceedings initiated u/s 147 beyond 6 years are void ab-initio as per the time limit prescribed u/s 149 - assessment order quashed
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