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...
Revision u/s 263 - Addition u/s 2(22)(e) - alleged loan & advances to concern - in assessment proceedings the Assessee had in fact placed audited statements which showed that sum received through AAIPL had been converted to shares allotted to AAIPL during AY 2014-15 - revenue has not been able to persuade this Court that the amount remained in the nature of loans and advances - no revision
Revision u/s 263 - Addition u/s 2(22)(e) - alleged loan & advances to concern - in assessment proceedings the Assessee had in fact placed audited statements which showed that sum received through AAIPL had been converted to shares allotted to AAIPL during AY 2014-15 - revenue has not been able to persuade this Court that the amount remained in the nature of loans and advances - no revision
Note: It is a system-generated summary and is for quick reference only.