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(2) - failure to take cognizance of certain judicial pronouncements - non-consideration of the judgments of the jurisdictional High Court and the Tribunal, which were specifically relied upon by the counsel during the course of the hearing of the appeal constitutes a mistake apparent from record - rectification allowable
Rectification u/s 254(2) - failure to take cognizance of certain judicial pronouncements - non-consideration of the judgments of the jurisdictional High Court and the Tribunal, which were specifically relied upon by the counsel during the course of the hearing of the appeal constitutes a mistake apparent from record - rectification allowable
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